CLA-2-85:OT:RR:NC:N2:209
Mr. Karl F. Krueger
Radix Group Int’l dba DHL Global Forwarding
2660 20th St.
Port Huron, MI 48060
RE: The tariff classification of fitness trackers/monitors and replacement wrist bands from China
Dear Mr. Krueger:
In your letter dated October 25, 2017, you requested a tariff classification ruling on behalf of your client, Polar Electro, Inc.
The items concerned are the Polar M200 and Polar M600 fitness tracker and their respective wrist bands (when imported separately). Each style of fitness tracker features a pedometer, internal GPS, a microcontroller, flash and SDRAM memory, Bluetooth capability, Wi-Fi capability, a watch, and a program to guide training.
Both models of fitness tracker have Wi-Fi capabilities allowing connection to social media, weather, maps etc. and Bluetooth to sync with a computer, phone or tablet for downloading workout or daily activity into a software program/application for tracking activity over time and for "coaching" to create and personalize workouts based on progress. Both of the models also
have multiple displays, which are changed by the user throughout the day depending on the
situation (watch, heart rate, email, etc.).
Both models track daily activity data such as active time, intensity zones, calories, steps,
distance, sleep time, qualify of sleep and daily record against goals in addition to work out
information such as heart rate, maximum heart rate, effort, speed and distance.
The replacement silicon wrist straps are exactly like wristwatch bands and are specific for
each model of fitness tracker. They are sold in different colors (black, blue, green pink, red, white and yellow) and are designed to either replace a broken strap or as a fashion color change.
The applicable subheading for the Polar M200 and Polar M600 fitness trackers will be 8517.62.0050, HTSUS, which provides for “Telephone sets…; other apparatus for the transmission or reception of voice, images or other data, including apparatus for communication in a wired or wireless network (such as a local or wide area network), other than transmission or reception apparatus of heading 8443, 8525, 8527 or 8528; parts thereof: Other apparatus for transmission or reception of voice, images or other data, including apparatus for communication in a wired or wireless network (such as a local or wide area network): Machines for the reception, conversion and transmission or regeneration of voice, images or other data, including switching and routing apparatus: Other.” The rate of duty will be Free.
The applicable subheading for the replacement silicone wrist straps/watch bands, when imported separately, will be 9113.90.8000, HTSUS, which provides for watch straps, watch bands, and watch bracelets, and parts thereof: other, other. The rate of duty is 1.8% 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 Steven Pollichino at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division