CLA-2-85:OT:RR:NC:N2:212
Saj Muzaffar
Inventx Limited
12 Blenheim Place, Steve Biko Way
Hounslow
London TW3 3ED
United Kingdom
RE: The tariff classification of an anti-snoring ring from the United Kingdom
Dear Mr. Muzaffar:
In your letter dated July 23, 2025, you requested a tariff classification ruling.
The merchandise under consideration is identified as the No Snore Ring, which is further described as a
smart anti-snoring device. The device is comprised of an internal Bluetooth module, a rechargeable battery,
and a vibration motor enclosed within the ring. The device is designed to be worn on the user’s finger during
sleep and wirelessly connects to a smartphone. The smartphone’s microphone detects the snoring sound of
the individual and transmits a signal to the ring. Once this signal is received, the ring activates a gentle
vibration to notify the wearer to change sleeping positions in order to help reduce or stop the snoring. We
note that the device does not track or monitor the sleep of the user, it only delivers the vibration initiated by
the smartphone.
In your request, you suggest that the correct classification for the subject smart ring is 8517.62.0090,
Harmonized Tariff Schedule of the Untied States (HTSUS). We disagree.
Heading 8517, HTSUS, provides in relevant part for “…other apparatus for the transmission or reception of
voice, images or other data, including apparatus for communication in a wired or wireless network…” The
item concerned is a ring to be worn on a finger that vibrates when a signal is received from a tethered
smartphone. The primary function of the device is to notify the user of their snoring through the vibration
action of the ring. In our view, the ring does not act as a transmitter or a receiver and any reception function
would be considered a secondary or support function. As such, classification in heading 8517, HTSUS, is not
applicable.
The applicable subheading for the No Snore Ring will be 8543.70.9860, HTSUS, which provides for
“Electrical machines and apparatus, having individual functions, not specified or included elsewhere in this
chapter; parts thereof: Other machines and apparatus: Other: Other.” The general rate of duty will be 2.6
percent ad valorem.
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 the United
Kingdom will be subject to an additional ad valorem rate of duty of 10 percent. At the time of entry, you
must report the Chapter 99 heading applicable to your product classification, i.e. 9903.02.66, in addition to
subheading 8543.70.9860, HTSUS, listed above.
In your request, you state that the No Snore Ring may be eligible for exclusion to Section 301 Trade
Remedies under 9903.88.67, HTSUS. Heading 9903.88.67 provides for product exclusions to products of
China classified in heading 9903.88.01. As you have stated the country of origin of the No Snore Ring is the
United Kingdom, neither heading 9903.88.01 nor 9903.88.67 applies. If circumstances change and the good
is manufactured in China, then the merchandise may be eligible for an exclusion. That determination,
however, will be made independently of this prospective ruling. For further information regarding this entry
issue, please contact your assigned CBP Center of Excellence and Expertise prior to the importation of the
goods.
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 Luke LePage at [email protected].
Sincerely,
(for)
James Forkan
Acting Director
National Commodity Specialist Division