CLA-2-90:OT:RR:NC:N1:405
Lydia Lorenzo
Zoetis, Inc.
10 Sylvan Way
Parsippany, NJ 07054
RE: The tariff classification of the SMARTBOW Eartag from China
Dear Ms. Lorenzo:
In your letter dated October 18, 2017, you requested a tariff classification ruling.
The product at issue, identified as the SMARTBOW Eartag, is described as a lightweight, rugged device intended to be mounted on animals. The eartag, which features an integrated radio chip, a temperature sensor, and an acceleration sensor, is designed to facilitate the real-time monitoring of cattle in a farm environment. The eartag’s radio chip tracks a given animal’s location in the barn, while the temperature sensor measures the ambient temperature. The acceleration sensor measures an animal’s rumination (the action of chewing the cud), as well as other patterns of motion that can indicate when an animal is in heat. Measurement data collected by the SMARTBOW Eartag are transmitted to a wireless receiver mounted in a barn, which in turn forwards the data to a local server at the farm for collection and analysis. A user can review the measurement data collected by the eartag on a computer, smartphone, or tablet.
Based on the information provided, the SMARTBOW Eartag is capable of tracking the location of an animal via the radio chip, measuring the ambient temperature, and measuring certain motion activities by means of the acceleration sensor. The eartag’s ability to measure motion enables it to measure and detect variations in an animal’s rumination (said to be a key indicator of animal health), and to help determine when an animal is in heat. Consequently, the SMARTBOW Eartag would be considered a composite good wherein the device’s ability to measure motion via the acceleration sensor, at a minimum, equally merits consideration in providing the essential character to the good in accordance with General Rule of Interpretation 3(c).
The applicable subheading for the SMARTBOW Eartag will be 9031.80.8085, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Measuring or checking instruments, appliances and machines, not specified or included elsewhere in this chapter; profile projectors; parts and accessories thereof: Other instruments, appliances and machines: Other: Other. The rate of duty will be 1.2% 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