CLA-2-85:OT:RR:NC:N2:212
CJ Erickson
Cowan, Liebowitz & Latman, P.C.
114 West 47th Street
New York, NY 10036
RE: The tariff classification of a smart dog collar from China
Dear Mr. Erickson:
In your letter dated October 23, 2025, you requested a tariff classification ruling on behalf of your client,
Protect Animals with Satellites, LLC.
The merchandise under consideration is identified as the Halo Collar, which is described as a smart dog
collar. The subject device is comprised of an electronic transceiver and training module encased within a
nylon covering and attached to an adjustable collar. The module incorporates two stimulation posts that are
designed to come in contact with the animal’s skin. The smart collar is designed to wirelessly connect,
through LTE, Wi-Fi, or Bluetooth technology, to a smart device, allowing the owner to communicate with
the dog and deliver corrections in the form of sound, vibrations, or electrical stimulation.
The smart collar further incorporates GPS technology, allowing the owner to draw virtual boundaries to keep
the dog within a defined space. When the animal gets close to the designated limits, the collar automatically
sends a correction impulse notifying the dog that it is too close to the boundary. The virtual boundary can be
drawn in any location and in a variety of configurations and sizes depending upon the needs of the owner.
The collar is used to keep the dog within the owner’s yard, a park, or anywhere else where the animal needs
to be kept close.
In your request, you suggest that the correct classification for the subject smart collar is under heading 8517,
Harmonized Tariff Schedule of the United States (HTSUS). We disagree.
Heading 8517, HTSUS, provides for electrical articles that have the specific function of transmitting and
receiving data. While the subject device incorporates Bluetooth, Wi-Fi, and LTE modules, it also has various
other components such as GPS, accelerometer, and other sensors to train the dog to stay within the pre-set
virtual fence without the need for a physical fence. The device delivers customizable feedback to teach the
dog to stay within the boundaries. It is the opinion of this office that the wireless communication capabilities
of this device are ancillary functions that support the principal function of training the dog to stay within the
virtual fence through various feedback such as sound, vibration, or static stimulation which are instantly
triggered when the dog strays from the pre-set boundaries. As such, classification under heading 8517,
HTSUS, is not applicable.
The applicable subheading for the Halo Collar 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 rate of duty will be 2.6% ad valorem.
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 10 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 8543.70.9860, 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. At the time of entry,
you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.01.25, in addition
to subheading 8543.70.9860, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 8543.70.9860, 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., 9903.88.02,
in addition to subheading 8543.70.9860, 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 Section 301 trade remedy, 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
https://www.cbp.gov/trade/remedies/301-certain-products-china
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)
Deborah Marinucci
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division