CLA-2-85:OT:RR:NC:N2:209
Alexander Koff
Venable LLP
750 E. Pratt Street, Suite 900
Baltimore, MD 21202
RE: The tariff classification of an ethernet switch from China
Dear Mr. Koff:
In your letter dated July 18, 2025, you requested a tariff classification ruling on behalf of your client,
Verifone, Inc.
The merchandise under consideration is described as an ethernet switch, Model Name: Orange D2, which is a
simple two-port switch bringing ethernet connectivity to any supported Verifone device with a dual role USB
interface for connecting to existing point-of-sale or accessories. The switch is used to seamlessly integrate
other Verifone devices into an existing network. This switch has two ethernet ports with one USB port along
with a DC power input. The switch is connected to a network using the two ethernet ports and different types
of payment terminals can be connected to the USB port.
The applicable subheading for the ethernet switch, Model Name: Orange D2, will be 8517.62.0020,
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 than transmission or reception apparatus of
heading 8443, 8525, 8527 or 8528; parts thereof: 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: Switching and routing apparatus.” The
general rate of duty will be Free.
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 8517.62.0020, HTSUS, listed above.
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 of China, Hong
Kong, and Macau will be subject to an additional ad valorem rate of duty of 10 percent. 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 8517.62.0020, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 8517.62.0020, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad
valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.04,
in addition to subheading 8517.62.0020, HTSUS, listed above.
The HTSUS is subject to periodic amendment, so you should exercise reasonable care in monitoring the
status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background
information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, including
information on exclusions and their effective dates, you may refer to the relevant parts of the USTR and CBP
websites, which are available at
https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and
https://www.cbp.gov/trade/programs-administration/trade-remedies, respectively.
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