CLA-2-90:OT:RR:NC:N1:105
Mike Mohseni
AutoMetrics Manufacturing Technologies Inc.
3600 Steeles Avenue E
Markham, Ontario L3R 9Z7
Canada
RE: The tariff classification and country of origin of an Industrial Data Acquisition Sensor Box
Dear Mr. Mohseni:
In your letter dated March 23, 2026, you requested a tariff classification and country of origin determination
ruling. Descriptive literature was provided for our review.
The subject merchandise is an Industrial Data Acquisition Sensor Box designed for monitoring electrical
parameters of industrial machinery. The device obtains current and voltage from connected industrial
machines, processes the data, and transmits digital data via WiFi, USB, or Ethernet connection. The unit is
Bluetooth enabled for wireless configuration and adjustments. The sensor is housed in a CNC-machined
aluminum enclosure, which is designed for indoor use in controlled environments.
We find the Industrial Data Acquisition Sensor Box to be similar to the DAQ-800 discussed in New York
Ruling N301112 (dated October 30, 2018). In the ruling it states:
Based on the information provided, the DAQ-800 performs no measurements or analyses itself, nor
does it serve to control any of the plant equipment to which it is connected. Instead, the DAQ-800
receives the analog signals that the measurement equipment in the plant equipment transmits and
converts it to digital data that can be displayed by the Shotscope program. In this respect, the
DAQ-800 serves a function similar to that of the data recorders described in Headquarters Ruling
Letter (HRL) H112722 (dated September 30, 2010). The data recorders in that ruling received
electrical signals from sensors incorporated into industrial machinery and translated said signals into
readable data that provided information on the operating status of the equipment. HRL H112722
found that the data recorders served as checking instruments of heading 9031, and classified them
accordingly.
The Industrial Data Acquisition Sensor Box is constructed with components from China, France, the U.S.A.,
Mexico, the United Kingdom, Canada, Taiwan, and the Philippines. The Chinese components include the
printed circuit board (PCB), the ESP32 module, power supply, rocker switch, wire, USB connector, housing,
bottom and top caps, and magnet. The French components include the banana jack sensor cables. The ring
connector, hex nut, and tapered heat-set plastic insert are of U.S.-origin. The female quick connect is from
Mexico, the USB-A adapter is from the United Kingdom, and the screws are from Taiwan and the
Philippines. The complete assembly process occurs in Canada along with the creation and flashing of the
firmware.
The assembly process begins with preparing the Chinese-origin enclosure, a black anodized aluminum
heatsink body featuring cooling fins on all four sides. This enclosure is placed on an anti-static mat with its
open cavity facing upward, its interior is inspected, and then cleaned for any debris. The four corner
mounting holes for the lid screws and the input/output (I/O) panel cutout on the front face are confirmed to be
clear and ready. Subsequently, the I/O panel, which serves as the front-facing aluminum plate for external
connectors is fitted with its components. This includes installing a rocker power switch, a USB Type-A port,
and two pairs of red and black banana jacks into their respective cutouts and holes, securing them with
screws and ensuring correct orientation. The RECOM AC-DC power supply module is then mounted inside
the enclosure body, adjacent to the I/O panel, with its AC input accessible and DC output terminals ready for
wiring.
Following the initial component installations, the PCB sub-assembly is prepared by mounting the
pre-assembled PCB, which includes an ESP32 module, onto the underside of the top lid plate using brass
standoffs. This assembly is secured with screws in a cross pattern to ensure even seating. The power circuit is
then wired, connecting the RED wire from the RECOM module to the rocker power switch and then to the
PCB’s positive terminal, while the BLACK wire connects directly to the PCB’s negative terminal. A chassis
ground wire is also connected from the RECOM module to the enclosure chassis for safety. The banana jacks
are wired to the corresponding Voltage and Current terminal blocks on the PCB, and the USB cable is routed
from the panel-mount port to the ESP32 module. After all wiring is completed and verified, including
insulating the banana jack terminals with liquid electrical tape to prevent shorting, a final comprehensive
check of all connections is performed before the lid is attached. The lid, with the PCB assembly facing
downward, is carefully lowered and secured with screws from the bottom of the enclosure. Finally, the I/O
panel, with all its connectors installed and wiring routed correctly, is aligned and secured to the front of the
enclosure.
The printed circuit board assembly (PCBA) incorporated within the device is a custom-designed printed
circuit board assembly fabricated in Canada. The board is designed around an ESP32-DEVKITC-32E
microcontroller module and two ADS8864 analog-to-digital converters (ADCs). Its primary function is to
receive analog electrical signals from external sensors connected to the device, condition and digitize those
signals, perform onboard data preprocessing, and transmit the resulting data to an external server or computer
for further analysis.
CLASSIFICATION
As suggested in your letter, which also aligns with ruling N301112, the applicable subheading for the
Industrial Data Acquisition Sensor Box will be 9031.80.8085, Harmonized Tariff Schedule of the United
States (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: Other
instruments, appliances and machines: Other: Other.” The 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/.
ORIGIN
In regard to marking, section 304 of the Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that
unless excepted, every article of foreign origin imported into the United States shall be marked in a
conspicuous place as legibly, indelibly, and permanently as the nature of the article (or its container) will
permit, in such a manner as to indicate to the ultimate purchaser in the United States, the English name of the
country of origin of the article. Congressional intent in enacting 19 U.S.C. 1304 was “that the ultimate
purchaser should be able to know by an inspection of the marking on the imported goods the country of
which the goods is the product. The evident purpose is to mark the goods so that at the time of purchase the
ultimate purchaser may, by knowing where the goods were produced, be able to buy or refuse to buy them, if
such marking should influence his will.” See United States v. Friedlander & Co., 27 C.C.P.A. 297, 302
(1940).
Section 134.1(b), CBP Regulations (19 CFR 134.1(b)), defines “country of origin” as the country of
manufacture, production, or growth of any article of foreign origin entering the United States. Further work
or material added to an article in another country must effect a substantial transformation in order to render
such other country the “country of origin” within the meaning of the marking laws and regulations.
Pursuant to section 102.0, interim regulations, related to the marking rules, tariff-rate quotas, and other
USMCA provisions, published in the Federal Register on July 6, 2021 (86 FR 35566), the rules set forth in
sections 102.1 through 102.18 and 102.20 determine the country of origin for marking purposes with respect
to goods imported from Canada and Mexico. Section 102.11 provides a required hierarchy for determining
the country of origin of a good for marking purposes, with the exception of textile and apparel goods which
are subject to the provisions of 19 CFR 102.21. See 19 CFR 102.11.
Applied in sequential order, 19 CFR 102.11(a) provides that the country of origin of a good is the country in
which:
(1) The good is wholly obtained or produced;
(2) The good is produced exclusively from domestic materials; or
(3) Each foreign material incorporated in that good undergoes an applicable change in tariff classification set
out in Part 102.20 and satisfies any other applicable requirements of that section, and all other applicable
requirements of these rules are satisfied.
Here, the Industrial Data Acquisition Sensor Box is neither “wholly obtained or produced” nor “produced
exclusively from domestic materials.” Consequently, paragraphs (a)(1) and (a)(2) cannot be used to
determine the country of origin of the Industrial Data Acquisition Sensor Box, and paragraph (a)(3) must be
applied to determine the origin of the finished article. As mentioned above, the subject assembly is classified
under subheading 9031.80.
The tariff shift requirement in Section 102.20 for a good classified within this subheading requires a change
to subheading 9031.80 from any other subheading.
The foreign materials include the Chinese, French, U.K., Taiwanese, and Philippine-origin components. The
Chinese components include the PCB, the ESP32 module, power supply, rocker switch, wire, USB
connector, housing, bottom and top caps, and magnet. The French components include the banana jack sensor
cables. The USB-A adapter is from the United Kingdom, and the screws are from Taiwan and the
Philippines.
Based on the manufacturing operations outlined previously, the tariff shift rule noted above is met. Each of
the non-originating components change to heading 9031 when assembled into the Industrial Data Acquisition
Sensor Box in Canada. We therefore find the country of origin of the Industrial Data Acquisition Sensor Box
to be Canada.
USMCA
The USMCA was signed by the Governments of the United States, Mexico, and Canada on November 30,
2018. The USMCA was approved by the U.S. Congress with the enactment on January 29, 2020, of the
USMCA Implementation Act, Pub. L. 116-113, 134 Stat. 11, 14 (19 U.S.C. § 4511(a)). General Note (GN)
11 of the Harmonized Tariff Schedule of the United States (HTSUS) implements the USMCA. GN 11(b) sets
forth the criteria for determining whether a good is an originating good for purposes of the USMCA. GN
11(b) states:
For the purposes of this note, a good imported into the customs territory of the United States from the
territory of a USMCA country, as defined in subdivision (l) of this note, is eligible for the preferential tariff
treatment provided for in the applicable subheading and quantitative limitations set forth in the tariff schedule
as a “good originating in the territory of a USMCA country” only if
(i) the good is a good wholly obtained or produced entirely in the territory of one or more USMCA countries;
(ii) the good is a good produced entirely in the territory of one or more USMCA countries, exclusively from
originating materials;
(iii) the good is a good produced entirely in the territory of one or more USMCA countries using
non-originating materials, if the good satisfies all applicable requirements set forth in this note (including the
provisions of subdivision (o)).
In your letter, you explain the final assembly of the product occurs in Canada using non-originating
components from China, France, the U.K., Taiwan, and the Philippines. Since the subject Industrial Data
Acquisition Sensor Box contains non-originating materials, it is not considered a good wholly obtained or
produced entirely in a USMCA country under GN 11(b)(i), nor is the product produced exclusively from
originating materials per GN 11(b)(ii).
Thus, we must determine whether the product qualifies under GN 11(b)(iii) and GN 11(o). The applicable
tariff shift rule in GN 11(o) for products classifiable under subheading 9031.80, HTSUS, requires a change to
subheading 9031.80 from any other heading.
The PCB, the ESP32 module, power supply, rocker switch, wire, USB connector, housing, bottom and top
caps, magnet, banana jack sensor cables, USB-A adapter, and the screws are sent to Canada where they are
combined with additional U.S., Mexican, and Canadian-origin components into a complete working unit. The
various foreign-origin components each undergo the required tariff shift.
Based on the facts provided, the goods described above qualify for USMCA preferential tariff treatment,
because they will meet the requirements of HTSUS General Note 11(b)(iii). The goods will therefore be
entitled to a Free rate of duty under the USMCA upon compliance with all applicable laws, regulations, and
agreements.
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 P. Forkan
Director
National Commodity Specialist Division