CLA-2-85:OT:RR:NC:N2:209
Anthony Zhu
Hanshow America Inc.
No. 1288 Kanghe Rd., Xiuzhou District, Jiaxing City,
Zhejiang Province,
China
RE: The tariff classification of Electronic Shelf Label (ESL) Controllers from China or Taiwan
Dear Mr.. Zhu:
In your letter dated July 15, 2025, you requested a tariff classification ruling.
The items concerned are referred to as Electronic Shelf Label (ESL) Controllers (Model Numbers HS
C09960 and HS C09979). These devices are wireless access points (AP). They are responsible for the data
transmission and information interaction between an electronic shelf label (i.e. pricing label used to display
the price of an item in a store) and a remote computer system that runs the electronic pricing system
architecture.
The electronic shelf label controller is responsible for the two-way data transmission between the price tag
work system (remote computer system) and the electronic shelf labels (shelf mounted electronic pricing label
displays). The product operates on the 2.4GHz wireless frequency band. This product connects to the price
tag work system via an Ethernet interface (POE) and establishes bidirectional 2.4GHz wireless
communication with electronic shelf labels to transmit data and images. The downlink is where this product
receives downlink packets from the price tag work system to perform updates, networking, upgrades, flash
updates, and global operations on electronic shelf labels. The uplink is where the product forwards heartbeat
packets and other information from the electronic shelf label to the price tag work system platform based on
the electronic shelf label wireless protocol standard.
The applicable subheading for the Electronic Shelf Label (ESL) Controllers (Model Numbers HS C09960
and HS C09979) will be 8517.62.0090, Harmonized Tariff Schedule of the United States (HTSUS), which
provides for “Telephone sets, including smartphones and other telephones for cellular networks or for other
wireless networks; other apparatus for the transmission or reception of voice, images or other data, including
apparatus for communication in a wired or wireless network (such as a local or wide area network)…: Other
apparatus for transmission or reception of voice, images or other data, including apparatus for
communication in a wired or wireless network (such as a local or wide area network): Machines for the
reception, conversion and transmission or regeneration of voice, images or other data, including switching
and routing apparatus: Other.” The general rate of duty will be Free.
Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise must
be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the
Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time products from all countries
will be subject to an additional 10 percent ad valorem rate of duty. Your product falls within an excepted
subheading. At the time of entry, you must report the Chapter 99 heading applicable to your product
classification, i.e. 9903.01.32, in addition to subheading 8517.62.0090, HTSUS, listed above.
Effective March 4, 2025, pursuant to U.S. Note 2(u) to Subchapter III, Chapter 99, all products of China and
Hong Kong as provided by heading 9903.01.24, HTSUS, other than products classifiable under headings
9903.01.21, 9903.01.22, and 9903.01.23, HTSUS, will be subject to an additional 20 percent ad valorem rate
of duty. At the time of entry, you must report the applicable Chapter 99 heading, i.e. 9903.01.24, in addition
to subheading 8517.62.0090, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheadings 8517.62.0090, HTSUS, unless specifically excluded, are subject to an additional 7.5 percent ad
valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.15,
in addition to subheading 8517.62.0090, HTSUS, listed above.
The tariffs and additional duties cited above are current as of this ruling’s issuance. Duty rates are provided
for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying
duty rates are provided at https://hts.usitc.gov/.
The holding set forth above applies only to the specific factual situation and merchandise description as
identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations
(CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the
information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and
complete in every material respect. In the event that the facts are modified in any way, or if the goods do not
conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and
Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2.
Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic
verification by CBP.
This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection
Regulations (19 C.F.R. 177).
A copy of the ruling or the control number indicated above should be provided with the entry documents
filed at the time this merchandise is imported. If you have any questions regarding the ruling, please contact
National Import Specialist Steven Pollichino at [email protected].
Sincerely,
(for)
James Forkan
Acting Director
National Commodity Specialist Division