CLA-2-90:OT:RR:NC:N1:105
Emile Coumans
SenseAnywhere BV
Bergrand 218, Roosendaal 4707AT
Netherlands
RE: The tariff classification of sensor modules and cables from China
Dear Mr. Coumans:
In your letter dated October 28, 2025, you requested a tariff classification ruling. Descriptive literature was
provided for our review.
The first item under consideration is described as a temperature and relative humidity (RH) module, which is
a compact connector sensor measuring 0–99% RH (non-condensing) and can monitor temperatures between
–40°C to +70°C. Its exposed sensors provide a fast response time, making it ideal for monitoring
refrigerators, freezers, small cold stores, and vehicle cargo spaces. The module meets EN12830:2018 Class
0.2°C accuracy across its entire temperature range and can serve as a reference device by placing it beside
existing loggers for on-site verification. Its small size allows installation in hard-to-reach or shielded areas,
and it can be connected to an AiroSensor 20-20-43 using SenseAnywhere Bus (SAB)-compatible extension
cables. Integrated electronics allow the module to be individually calibrated for precise measurements.
The second item under consideration is described as the PT100 temperature probe, which is a smart digital
SAB-interface temperature sensor designed for ultra-low temperatures down to -200°C, suitable for
cryogenic applications. Using a Class A thin-film Pt100 element, it provides accurate measurements over a
wide range. Since the measurement electronics are built into the connector, only the probe requires
calibration, not the AiroSensor 20-20-43 it connects to.
The third item under consideration is described as the 0-10V input module, which is a smart device that
digitizes signals from any 0–10V analogue sensor, enabling high-accuracy monitoring of third-party devices
such as carbon dioxide sensors, pressure sensors, or particle counters. The module converts analogue data to
digital and forwards it via the SAB interface to an AiroSensor 20-20-43, which uploads measurements to
SAClient. All values appear in one system with real-time visibility, alarms, reporting, and complete audit
trails.
The fourth item under consideration is described as the 4-20mA input module, which is a smart device that
provides the same functionality as the third item but for sensors with a 4–20mA output, digitizing their
analogue signals for integration into the SenseAnywhere system. Connected through the SAB interface to an
AiroSensor 20-20-43, it also transmits all measurements to SAClient for centralized monitoring, alarms,
reporting, and downloadable audit trails.
In your letter, you suggest the applicable heading for each of the four items to be 8517, Harmonized Tariff
Schedule of the United 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 (such as a local or wide area network).” The items concerned
are primarily used to capture/determine a type of measurement. They have a secondary function of
transmitting that information to an end use device. Classification under heading 8517, HTSUS, is precluded
because the devices concerned are composite goods (Section XVI Note 3 and Chapter 90 Note 3) which
execute the principal function of determining/calculating a measurement. The ability of the units to transmit
that information to a remote end use device would be considered secondary or support functions.
Additionally, as per the Explanatory Notes to heading 8517, carrier-current and other transmitters and
receivers which form a single unit with analogue or digital telemetering instruments or apparatus are
excluded from heading 8517. Measurement apparatus of Chapter 90 are also excluded from classification
within Chapter 85. (Section Note XVI Note 1(m) excludes articles of Chapter 90). Therefore, classification
within heading 8517. HTSUS, is not applicable.
The applicable subheading for the temperature and RH module will be 9025.80.1000, HTSUS, which
provides for “Hydrometers and similar floating instruments, thermometers, pyrometers, barometers,
hygrometers and psychrometers, recording or not, and any combination of these instruments; parts and
accessories thereof: Other instruments: Electrical.” The general rate of duty will be 1.7 percent ad valorem.
The applicable subheading for the PT100 temperature probe will be 9025.19.8085, HTSUS, which provides
for “Hydrometers and similar floating instruments, thermometers, pyrometers, barometers, hygrometers and
psychrometers, recording or not, and any combination of these instruments; parts and accessories thereof:
Thermometers and pyrometers, not combined with other instruments: Other: Other: Other: Other.” The
general rate of duty will be free.
The applicable subheading for the 0-10V input module and the 4-20mA input module 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: Other: Other.”
The general rate of duty will be 2.6 percent 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 subheadings 9025.80.1000, 9025.19.8085, and 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 subheadings 9025.80.1000, 9025.19.8085, and 8543.70.9860, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheadings 9025.80.1000, 9025.19.8085, and 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 subheadings 9025.80.1000, 9025.19.8085, and
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 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 Jason Christie at [email protected].
Sincerely,
(for)
Deborah Marinucci
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division