CLA-2-87:OT:RR:NC:N1:101
Konnie Gurung, Customs Compliance Manager
Quality Bicycle Products, Inc.
6400 West 105th Street
Bloomington, MN 55438
RE: The tariff classification of two (2) wireless bicycle shifting systems from an unspecified country
Dear Ms. Gurung:
In your letter dated April 22, 2016 you requested a tariff classification ruling on behalf of Quality Bicycle Products, Inc. (QBP).
The first item has been identified as the “SRAM RED eTAP Electric Road Kit. The Road Kit contains electric brake-shifter levers, front and rear derailleurs, battery charger and USB stick. The purpose of the SRAM RED eTap Shifters is to communicate up and down-shifting with the derailleurs, as well as control front and rear brakes. You state that rather than being equipped with cable wires to mechanically push and pull the derailleurs shifting mechanisms the SRAM RED eTap shifters are equipped with a wireless communication protocol. The communication protocol requires that the eTap shifter and derailleur components can only be used together as a complete kit; these components cannot be used with conventional cable-operated components.
You state the SRAM RED eTap Front Derailleur takes signals from the eTap Shifters for quick, confident front shifting. The SRAM RED eTap Rear Derailleur also accepts signals from the eTap Shifters and wirelessly shifts the rear gears of the bicycle instantly. SRAM RED eTap components operate wirelessly using a 128-bit rolling encryption to drive the front and rear derailleur motors via the two shifters. Actuating the left shifter moves the rear derailleur inward and the right shifter drives the rear derailleur motor outward. Actuating both shifter buttons at the same time drives the front derailleur motion either inward or outward. Both Front and Rear Derailleurs contain identical, interchangeable lithium-polymer battery packs. You state the battery capacity is roughly 1,000 km or 60 hours of riding time for the rear derailleur and 50% longer than that for the front derailleur. The Battery Charger is used to recharge the batteries. The batteries have their own charging cradle powered by USB and can be plugged into a computer or into SRAM's wall adapter. The USB Stick is the interface to update the firmware once SRAM has developed an update.
The second item has been identified as the “SRAM eTap Electric Aero Kit”. The Aero Kit contains “Blip” shifters, front and rear derailleurs, battery charger and USB stick. You state that the SRAM Tap Blips are the shifting mechanism that was created to use on both standard road and your aero/time trial handlebars. The Blips allow a rider to adjust gears with the touch of a finger and connect into the BlipBox, which manages the wireless shifting through AIREA. You state that the combination of the Blips and BlipBox in the Aero kit perform the same shifting function as the eTap Shifters in the Road Kit. The Aero Kit includes the same SRAM RED eTap Front Derailleur, SRAM RED eTap Rear Derailleur, Battery Charger and USB Stick as in the SRAM RED eTAP Electric Road Kit.
You claim that, because the shift actuation function in the Aero Kit is performed by the BlipBox, conventional brake levers, which are not included in either kit, may be used with the Aero Kit.
The applicable subheading for the SRAM RED eTAP Electric Road Kit and SRAM eTap Electric Aero Kit will be 8714.99.5000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Parts and accessories of vehicles of headings 8711 to 8713: Other: Derailleurs and parts thereof”. 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 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 Matthew Sullivan at [email protected].
Sincerely,
Deborah C. Marinucci
Acting Director
National Commodity Specialist Division