CLA-2 CO:R:C:M 950440 MBR
8517.40.50
Mr. Gordon W. Larson
Rudolph Miles & Sons
4950 Gateway East
P.O. Box 144
El Paso, Texas 79942
RE: Home Alarm Systems; Components Shipped in Bulk Form; Control
Panel Printed Circuit Boards; Home Security Panels; 300 MHz
Radio Frequency Transmitters and Receivers; Telephonic Dialer
Boards; Infrared Detectors Incorporating RF Transmitters;
Parts
Dear Mr. Larson:
This is in reply to your letter of October 1, 1991, requesting
classification of home alarm system components imported from
Mexico, on behalf of Honeywell Protective Services Division, under
the Harmonized Tariff Schedule of the United States (HTSUS).
FACTS:
Presently, you import the following home alarm system
components from Mexico:
-Control panel boards for systems 1500, 1500e MOD II, 2000e,
and 6000 (future system).
-Alphanumeric home security panel and security panels for
system 1500, 1500e MOD II, 2000, and 6000.
-300 MHz Receiver.
-300 MHz Transmitters, models TH8802, and T8803.
-System 1500 dialer board.
-2-
-Hardwire expander boards, hardwire module boards, multiple
receiver adapter boards, receiver interface boards, remote
receiver adapter boards, PLC boards, alphanumeric HSP adapter
boards, and end of line module boards.
ISSUE:
What are the classifications of home alarm system components,
under the Harmonized Tariff Schedule of the United States (HTSUS)?
LAW AND ANALYSIS:
The General Rules of Interpretation (GRI's) to the HTSUS
govern the classification of goods in the tariff schedule. GRI 1
states, in pertinent part:
...classification shall be determined according to
the terms of the headings and any relative section
or chapter notes....
HQ 088891, dated June 21, 1991, determined that bulk shipments
of the instant merchandise "would not be considered to have the
essential character of a complete home alarm system, because they
are apparently nothing more than disparate components shipped in
bulk form." Furthermore, HQ 088891 held that "[i]f the 'upgrade
kits' (consisting of up to 8 Alphanumeric HSPs and Alphanumeric
Adapter Boards) are goods put up in sets for retail sale, they are
determined to have the essential character of the Alphanumeric
HSPs."
HQ 088595, I/A 4/91, dated September 12, 1991, held that a
"control panel" printed circuit board without the keypad, was
classifiable under subheading 8531.90.00, HTSUS, which provides
for: "[e]lectrical sound or visual signaling apparatus (for
example, bells, sirens, indicator panels, burglar or fire alarms),
other than those of heading 8512 or 8530; parts thereof: [p]arts."
Therefore, the control panel boards for systems 1500, 1500e MOD II,
2000e, and 6000 are similarly classifiable under subheading
8531.90.00, HTSUS.
The "Home Security Panel" (HSP) consists of a digital key, a
sounding device for audible alarms, a point identification display,
six touch switches, and 12 indicator lights. HQ 087876, dated
December 27, 1991, held that "Indicator Panel/Keypad Units" for
home alarm systems were classifiable under subheading 8531.20.00,
HTSUS, which provides for: "[e]lectrical sound or visual signaling
apparatus (for example, bells, sirens, indicator panels, burglar or
fire alarms), other than those of heading 8512 or 8530; parts
thereof: [i]ndicator panels incorporating liquid crystal devices
(LCD's) or light emitting diodes (LED's)." Therefore, the
"alphanumeric home security panel" and security panels for the
-3-
1500, 1500e MOD II, 2000, and 6000 systems, are similarly
classifiable in subheading 8531.20.00. HTSUS.
The 300 MHz radio frequency transmitters (models TH8802, and
T8803) transmit data regarding the occurrence of events such as the
opening or closing of a circuit (window/door detector) or a panic
button signal. Pursuant to Section XVI, Legal Note 2(a), regarding
parts, such transmission apparatus for radio broadcasting is
classifiable in subheading 8525.10.80, HTSUS, which provides for:
"[t]ransmission apparatus for...radiobroadcasting...: [o]ther:
[t]ransmitters."
The infrared detectors, incorporating RF transmitters, are
composite machines. The principal function is determined to be
that of detection for an alarm system. Therefore, pusuant to
Section XVI, Legal Note 3., the infrared detectors incorporating RF
transmitters are classifiable in subheading 8531.90.00, HTSUS.
The 300 MHz radio frequency receiver is used to receive
signals from transmitters and relay the signal to the control panel
for processing. Pursuant to Section XVI, Legal Note 2(a),
regarding parts, such radio frequency receivers are classifiable in
subheading 8527.39.00, HTSUS, which provides for: "[r]eception
apparatus for...radiobroadcasting...: [o]ther radiobroadcast
receivers...: [o]ther."
The optional system 1500 dialer board utilizes telephone lines
to dial up and signal a remote Customer Service Center. Pursuant
to Section XVI, Legal Note 2(a), regarding parts, such telephonic
apparatus is classifiable in subheading 8517.40.50, HTSUS, which
provides for: "[e]lectrical apparatus for line telephony or
telegraphy, including such apparatus for carrier-current line
systems; parts thereof: [o]ther apparatus, for carrier-current line
systems: [o]ther: [t]elephonic."
The hardwire expander boards, hardwire module boards, multiple
receiver adapter boards, receiver interface boards, remote receiver
adapter boards, PLC boards, alphanumeric HSP adapter boards, and
end of line module boards, are all parts of the alarm system, and
pursuant to Section XVI, Legal Note 2.(b), are classifiable in
subheading 8531.90.00, HTSUS, which provides for: "[e]lectrical
sound or visual signaling apparatus (for example, bells, sirens,
indicator panels, burglar or fire alarms), other than those of
heading 8512 or 8530; parts thereof: [p]arts."
HOLDING:
The control panel boards for systems 1500, 1500e MOD II,
2000e, and 6000 are classifiable under subheading 8531.90.00,
HTSUS.
-4-
The "Home Security Panels" (HSPs) are classifiable under
subheading 8531.20.00, HTSUS.
The 300 MHz radio frequency transmitters (models TH8802, and
T8803) are classifiable in subheading 8525.10.80, HTSUS.
The infrared detectors incorporating transmitters are
classifiable in subheading 8531.90.00, HTSUS.
The 300 MHz radio frequency receivers are classifiable in
subheading 8527.39.00, HTSUS.
The system 1500 dialer boards are classifiable in subheading
8517.40.50, HTSUS.
The hardwire expander boards, hardwire module boards, multiple
receiver adapter boards, receiver interface boards, remote receiver
adapter boards, PLC boards, alphanumeric HSP adapter boards, and
end of line module boards, are classifiable in subheading
8531.90.00, HTSUS.
Sincerely,
John Durant, Director
Commercial Rulings Division