CLA-2-85:OT:RR:NC:1:120
Mr. David Gomez
World Exchange, Inc. 11205 S. La Cienega Blvd.
Los Angeles, CA 90045
RE: The tariff classification of three Wi-Fi-based home networking products from Taiwan and China
Dear Mr. Gomez: In your letter dated July 17, 2014 you requested a tariff classification ruling on behalf of your client, D-Link Systems, Inc. The samples are being returned as requested. The merchandise under consideration is the D-Link W-Fi Smart Plug Lite, model number DSP-W110; the D-Link Wi-Fi Smart Plug, model number DSP-W215; and the D-Link Wi-Fi Pyroelectric infrared (PIR) Motion Sensor, model number DCH-S150, all imported separately from each other.
The D-Link Wi-Fi Smart Plug Lite, model number DSP-W110, is a three-prong plug-in module with a three-plug outlet used for the insertion and control of various electric devices inside the home, such as a lamp and fan. It is controlled by a mobile app which sends a signal (or command) to the module, thereby causing its circuit to close or open and turn a device on or off. The module is encased in a plastic housing, measuring approximately 3 ½ inches in length by 2 inches in width and 1 ½ inches in depth, with three control buttons: a power button, a WPS (Wireless Protected Setup) button to connect to the home network; and a reset button. It is rated for up to 120 Volts (V) AC and 15 Amps (A). From the information provided by you, the Smart Plug incorporates switches, relays, fuses, contacts, plugs and sockets. It does not have built-in surge protection nor does it contain components that divert a voltage spike to ground.
The D-Link Wi-Fi Smart Plug, model number DSP-W215, is similar to model number DSP-W110 in styling, construction and function in noting the following differentiating features: it is slightly larger in size; it has two control buttons (a power button and a WPS button); and it has a built-in temperature sensor.
The D-Link Wi-Fi PIR Motion Sensor, model number DCH-S150, is a two-prong plug-in module, with a WPS button, which operates with the Smart Plug model numbers DSP-W110 and DSP-W215. The sensor uses infrared waves to detect the motion of an object within a range of 26 feet and sends a signal to the user’s phone when motion is detected. This signal is also transmitted to the Smart Plug(s), thereby directing the desired action. It is encased in a plastic housing measuring approximately 2 inches in length by 2 inches in width by 1 ½ inches in depth. It is rated for up to 120 Volts (V) and 0.1 Amps (A).
The applicable subheading for the D-Link W-Fi Smart Plug Lite, model number DSP-W110, and the D-Link Wi-Fi Smart Plug, model number DSP-W215, will be 8537.10.9070, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "Boards, panels, consoles, desks, cabinets and other bases, equipped with two or more apparatus of heading 8535 or 8536, for electric control or the distribution of electricity…: For a voltage not exceeding 1,000 V: Other: Other: Other." The rate of duty will be 2.7 percent ad valorem.
The applicable subheading for the D-Link DCH-S150 PIR Motion Sensor will be 8543.70.4000, HTSUS, which provides for “Electrical machines and apparatus, having individual functions, not specified or included elsewhere in this chapter; parts thereof: Other machines and apparatus: Electric synchros and transducers; flight data recorders; defrosters and demisters with electric resistors for aircraft. The rate of duty is 2.6 ad valorem.
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 Denise M. Faingar at [email protected]. Sincerely,
Gwenn Klein Kirschner
Director
National Commodity Specialist Division