CLA-2-90:OT:RR:NC:N1:405
Laura Arnold
J Royal
2441 Salem Park Drive
Winston Salem, NC 2712
RE: The tariff classification of a digital encoder register for water meters from Malaysia
Dear Ms. Arnold:
In your letter dated July 6, 2017, on behalf of GWF MessSysteme AG, you requested a tariff classification ruling.
The product at issue, identified as the Lydia Module Assembly, is described as a digital encoder register used in water metering systems. Per the information provided with your submission, the Lydia Module Assembly is designed to be used in water meter reading systems to keep track of the amount of water that has flowed through a given pipe in a water system. Compatible with several models of water meter, the product features an eight-wheel mechanical odometer that serves to display the amount of water that has passed through the meter. In addition to providing an analog reading of water flow, the module has the ability to convert the water usage data into a digital format that can be transmitted to another device (a touch module or radio frequency device) for remote reading.
Based on the information and technical specifications provided, the Lydia Module Assembly operates in a matter similar to that of the Absolute Digital Encoder Registers described in Headquarters Ruling Letter (HRL) 968089, dated May 1, 2006. Like the products described in that ruling, the Lydia Module is specially designed to work with a water meter, provides an analog reading of water consumption via a mechanical odometer, and converts the water usage data into a digital format to facilitate remote meter reading. As a result, and in accordance with the determination of HRL 968089, the Lydia Module Assembly would be classified as a part of the water meter with which it is used.
The applicable subheading for the Lydia Module Assembly will be 9028.90.0080, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Gas, liquid or electricity supply meters, including calibrating meters thereof; parts and accessories thereof: Parts and Accessories: Other. The rate of duty will be 2.4% 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 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 Evan Conceicao at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division