CLA-2-85:OT:RR:NC:N1:109
Ms. Stephanie Park
LG Electronics USA, Incorporated
1000 Sylvan Avenue
Englewood Cliffs, NJ 07632
RE: The tariff classification of wireless charging covers from South Korea.
Dear Ms. Park:
In your letter dated July 19, 2012, you requested a tariff classification ruling.
The merchandise subject to this ruling is wireless charging covers. They are identified as model numbers WCC-920 and WCC-930. WCC-920 is specifically designed to fit on the back of an LG VS920 cell phone and WCC-930 is specifically designed to fit on the back of an LG VS930 cell phone. They are utilized in conjunction with LG Electronic’s WCP-700 wireless charging pad in order to recharge the batteries within LG’s VS920 and VS930 cell phones. WCC-930 is similar to the WCC-920 except that the WCC-930 is Near Field Communication (NFC) enabled, which allows it to communicate wirelessly with other wireless devices.
In order to recharge the batteries of both the LG VS920/VS930 cell phones, the battery cover of the VS920 must be removed and replaced with the WCC-920 wireless charging cover and the battery cover of the VS930 must be removed and replaced with the WCC-930 charging cover. The LG cell phones (VS920/VS930) must be turned on and placed onto the WCP-700 wireless charging pad in order to initiate wireless recharging of the cell phone batteries.
The WCP-700 operates on magnetic induction technology with the use of two coils; a transmitter coil and a receiver coil. The transmitter coil is located within the WCP-700 wireless charging pad. The receiver coil is located within the WCC-920 and WCC-930. An alternating current in the transmitter coil of the WCP-700 generates a magnetic field which induces a voltage in the receiver coil of the WCC-920/WCC-930, depending on which cell phone is placed on the WCP-700 wireless charging pad. The voltage that is generated is used to recharge the cell phone batteries.
The WCC-920 contains a receiver coil. When the alternating current in the transmitter coil of the WCP-700 generates a magnetic field it induces a voltage in the receiver coil so that the battery in the VS920 can be recharged. As such, the WCC-920 is an inductor.
The WCC-930 is similar to the WCC-920 in that it contains a receiver coil and induces a voltage, as a result of the magnetic field generated by the WCP-700, which is used to recharge the battery within the VS920 LG cell phone. Therefore it executes the function of an inductor of heading 8504. However, the WCC-930 also has a Near Field Communication (NFC) feature, which is a set of standards for smart phones and similar devices to establish radio communication with each other by touching them together or bringing them into close proximity, usually no more than a few centimeters. Present applications of the NFC include contactless transactions, data exchange, and simplified setup of more complex communications such as Wi-Fi, which are functions provided for within heading 8517.
The WCC-930 is a composite machine designed for the purpose of performing two alternative functions; inductance and wireless communication. Legal Note 3 to Section XVI states that unless the context otherwise requires, composite machines consisting of two or more machines fitted together to form a whole and other machines designed for the purpose of performing two or more complementary or alternative functions are to be classified as if consisting only of that component or as being that machine which performs the principal function. This office has not found that the WCC-930 has one principal function; both functions equally merit consideration. As such, General Rule of Interpretation (GRI) 3 (c) has been applied. GRI 3 (c) states that when goods cannot be classified by reference to 3(a) or 3(b), they shall be classified under the heading which occurs last in numerical order among those which equally merit consideration. The two headings that merit equal consideration are 8504 and 8517. Therefore, since heading 8517 occurs last in numerical order, the WCC-930 is classified within that heading.
The applicable subheading for the wireless charging cover model # WCC-920 will be 8504.50.4000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electrical transformers, static converters (for example, rectifiers) and inductors…Other inductors: For telecommunication apparatus.” The rate of duty will be free.
The applicable subheading for the wireless charging cover model # WCC-930 will be 8517.62.0050, (HTSUS), which provides for “Machines for the reception, conversion, and transmission or regeneration of voice, images or other data, including switching and routing apparatus: Other.” The 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 World Wide Web at http://www.usitc.gov/tata/hts/.
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 Linda Hackett at (646) 733-3015.
Sincerely,
Thomas J. Russo
Director
National Commodity Specialist Division