CLA-2-85:OT:RR:NC:N2:120
Cathy Spencer
Freight Expediters
6920 Engle Rd. Suite II
Middleburg Heights, OH 44130
RE: The tariff classification of a pan-tilt control board from Great Britain
Dear Ms. Spencer:
In your letter dated August 17, 2017 you requested a tariff classification ruling on behalf of your client, International Products Sourcing Group.
The merchandise under consideration is referred to as the Pan-Tilt HAT, PN 298018 and is said to be an accessory component used exclusively with the Raspberry Pi. Accessories for the Raspberry Pi are commonly referred to as a “HAT” or a “pHAT.” These acronyms represent the method of affixing the devices to the Raspberry Pi and simply stand for the term “Hardware Attached on Top.” The term “pHAT” merely identifies a smaller version of the HAT. Generally, HATs and pHATs are printed circuit board assemblies that perform a variety of specific functions and incorporate a mounted EEPROM which identifies the device to the Raspberry Pi.
The subject Pan-Tilt HAT is comprised of a retail package containing a printed circuit board assembly (PCBA) controller, mounting plates and hardware, and a preassembled electric servo assembly. The control PCBA is intended to be mounted onto a Raspberry Pi general purpose input/output connector and the servo assembly is mounted to the control PCBA. The instant kit consists of two or more different articles that are, prima facie, classifiable in different headings. The Pan-Tilt HAT also consists of articles put up together to carry out a specific activity (i.e., camera movement). Finally, the articles are put up in a manner suitable for sale directly to users without repacking. Therefore, the kit in question is described within the meaning of "goods put up in sets for retail sale."
General Rule of Interpretation ("GRI") 3(b) states in part that goods put up in sets for retail sale, which cannot be classified by reference to GRI 3(a), are to be classified as if they consisted of the component which gives them their essential character. It is the opinion of this office that the servo assembly imparts the essential character of the Pan-Tilt HAT Kit.
The Pan-Tilt HAT servo assembly consists of two servos which provide multi-axis vertical and horizontal motion, electrical wires, and a plastic mount for affixing a camera and light. The servos are said to operate on 5V DC and require a 2.5 Amp power supply, and have a combined maximum power output of 25 Watts. The camera and/or LED light module are not included in the kit.
In your submission you suggest classification in subheading 8529.90.8100, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Parts suitable for use solely or principally with the apparatus of headings 8525 to 8528: Other parts of articles of headings 8525 and 8527: Of television apparatus: For television cameras: Other.” However, this merchandise is not a “part” of the camera nor is it designed solely for use with the camera.
As an alternative you suggest heading 8543 as an appropriate classification for the Pan-Tilt HAT Kit. We disagree as classification in heading 8543 requires that merchandise must have an individual function that is not specified or included elsewhere, and the Pan-Tilt HAT servo assembly is more accurately described in heading 8501.
The applicable subheading for the Pan-Tilt HAT Kit will be 8501.10.6060, HTSUS, which provides for "Electric motors…: Motors of an output not exceeding 37.5 W: Of 18.65 W or more but not exceeding 37.5 W: DC: Other. The general rate of duty will be 2.8%.
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 Karl Moosbrugger at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division