CLA-2-85:OT:RR:NC:N2:209
Eric Segal
Panasonic Corporation of North America
Two Riverfront Plaza
Newark, NJ 07102
RE: The tariff classification of a telematic control unit from Spain
Dear Mr. Segal:
In your letter dated May 6, 2019, you requested a tariff classification ruling.
The items concerned are referred to as "Telematic Control Units" (TCU), model numbers 51986538 and 51986539.
The TCU is a cellular communication device that is installed within a vehicle and connects to the Controller Area Network (CAN) bus, Body Control Module (BCM), and battery line voltage (VBATT). It allows the vehicle to communicate CAN bus data, location data, and vehicle security information to a backend server infrastructure.
The TCU has an internal battery capable of sustaining TCU operations for security purposes, BLE 4.2 connectivity, a LTE/4G/3G/2G cell modem, GPS/GLOANASS functionality, internal cellular and GPS antennas. The GPS functionality provides mobile phone access via the TCU to a vehicle’s position and routes the phone to that vehicle. The vehicle does not use the GPS from the TCU to perform routing or navigation functions.
The applicable subheading for the "Telematic Control Units" (TCU), model numbers 51986538 and 51986539 will be 8517.62.0090, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Telephone sets, including telephones for cellular networks or for other wireless networks; 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), other than transmission or reception apparatus of heading 8443, 8525, 8527 or 8528; parts thereof: Other apparatus for 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): Machines for the reception, conversion and transmission or regeneration of voice, images or other data, including switching and routing apparatus: Other.” The general rate of duty will be Free.
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 on the World Wide Web at https://hts.usitc.gov/current.
This ruling is being issued under the provisions of Part 177 of the Customs 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, contact National Import Specialist Steven Pollichino at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division