CLA-2-85:OT:RR:NC:N2:209

Gary Jones
L3Harris.Technologies, Inc.
201 12th St. S.
Arlington, VA 22202

RE: The tariff classification of remote mount control unit from Japan

Dear Mr. Jones:

In your letter dated August 27, 2025, you requested a tariff classification ruling.

The merchandise under consideration is referred to as the XL Onboard Control Unit, Model Numbers 14050-1150-01 and 14050-1150-04, which is a remote mount control unit for a mobile radio system. The device is comprised of a speaker, color LCD display, physical knobs and buttons to allow users to control the unit. The control unit also features Wi-Fi, Bluetooth along with components enabling reception, processing, Ethernet switching and routing for transmission and reception of voice and data. It is designed to be mounted in a vehicle with a handheld digital microphone.

The control unit converts voice samples from the microphone into VoIP packets to send over wired Ethernet interface to networked devices including Land Mobile Radio transceiver and the control unit can also receive the voice data in the form of VoIP packets converting it into amplified audio signals to be reproduced using the internal speaker or via external speaker.

The device includes switching and routing capabilities that enable it to route received voice and data over wired/wireless communication interfaces such as Wi-Fi or Bluetooth. It supports transmission or control data in the form of IP packets over a wired Ethernet networking interface to provide control of attached equipment. It also supports transmitting and receiving voice and control data over a Wide Area Network with other commercially available routers and networking equipment. We note that the device includes MAC address table and both static and dynamic IP addresses.

The applicable subheading for the XL Onboard Control Unit, Model Numbers 14050-1150-01 and 14050-1150-04 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 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 Japan with an ad valorem (or ad valorem equivalent) rate of duty under column 1-General less than 15 percent will be subject to an additional ad valorem rate of duty of 15 percent minus the column 1-General duty rate. 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.

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)
Denise Faingar
Acting Director
National Commodity Specialist Division