CLA-2-90:OT:RR:NC:N1:105
Emily Levanger
Franklin Sensors
6675 N Pollard Lane
Meridian, ID 83646
RE: The tariff classification of a digital torpedo level body from China
Dear Ms. Levanger:
In your letter dated February 13, 2026, you requested a tariff classification ruling. Descriptive literature,
pictures, and a sample were provided for our review.
The item under consideration is described as the body of a digital torpedo level, crafted from clear
polycarbonate with a permanently attached magnet along the bottom. This pre-manufactured plastic
component is precisely sized and shaped to form the complete digital torpedo level, featuring uniquely sized
cutouts for bubble levels and a dedicated space for electronic components. It serves as the foundational
structure for the final polycarbonate digital level.
This completed digital torpedo level features an electronic center section that illuminates green when
perfectly level, whether horizontally or vertically, and displays red LED lights when off-level. This central
electronic component is equipped with an on/off button, the LED indicators, and is powered by a single AA
battery. In addition to the electronics, the level also incorporates traditional bubble levels, with a vertical
bubble on the left side and a horizontal bubble on the right. These twelve-inch levels are specifically
designed for precision work by carpenters and DIY enthusiasts.
In your letter, you suggest the applicable subheading for the body of the digital torpedo level to be
9015.90.0130, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Surveying
(including photogrammetrical surveying), hydrographic, oceanographic, hydrological, meteorological or
geophysical instruments and appliances, excluding compasses; rangefinders; parts and accessories thereof:
Parts and accessories: Of levels.” We disagree. The levels that are classified in heading 9015 are specifically
designed for surveying. The level body for the completed torpedo level is designed for everyday use by
homeowners and construction workers, not by surveyors. Therefore, heading 9015 is excluded from
consideration.
Accordingly, the applicable subheading for the body of a digital torpedo level will be 9031.90.9195, HTSUS,
which provides for “Measuring or checking instruments, appliances and machines, not specified or included
elsewhere in this chapter; profile projectors; parts and accessories thereof: Parts and accessories: Other:
Other: Other.” The general rate of duty will be free.
The 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/.
This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other
charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other
duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the
classification stated above, the merchandise covered by this ruling may also need to be reported with either
the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions
covering exceptions to such tariffs.
For further information to assist with the importation process, please refer to the frequently updated Cargo
Systems Messaging Service (CSMS) messages at
https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and the Trade Remedies page at
https://www.cbp.gov/trade/programs-administration/trade-remedies.
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)
James Forkan
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division