CLA-2-90:OT:RR:NC:N1:105
Nina Carrico
Ingram Micro
3351 Michelson Drive, Suite 100
Irvine, CA 92612
RE: The tariff classification of the ZOZOSUIT from Vietnam and China
Dear Ms. Carrico:
In your letter dated February 1, 2018, on behalf of Start Today USA, Inc., you requested a tariff classification ruling. A sample was provided.
The product at issue, identified as the ZOZOSUIT, is described as a unisex measuring device used to precisely measure every part of the human body. The ZOZOSUIT comes in two pieces, is composed of a combination of polyester and polyurethane, and incorporates an array of stretchable sensors throughout the body of the product. The ZOZOSUIT is intended to be used to facilitate purchases from a related apparel e-commerce company. The measurements taken by the suit will enable the e-commerce company to recommend the size and style of clothing that will best fit the customer.
To operate the ZOZOSUIT, a user will put on both the top and bottom portion of the suit over their undergarments (the ZOZOSUIT is designed to be skintight). Once activated, the suit’s sensors perform detailed measurements of the user’s body (up to 15,000 measurements are taken). There are four electronic devices permanently affixed to the suit. The electronic devices collect the measurement data from the sensors and relay it to a user’s smartphone via Bluetooth, where it can be viewed by means of a downloadable app. The entire measurement process is said to take no more than a few seconds, after which point the user would deactivate the ZOZOSUIT and remove it.
Based on the information provided, the ZOZOSUIT is designed for the express purpose of performing detailed measurements of a user’s body dimensions. The product’s specification sheet indicates that the ZOZOSUIT is to be worn solely during the measurement process, and is not suitable for extended wear. The sensors and electronic devices cannot be removed from the suit, nor can the suit be washed or exposed to moisture. The ZOZOSUIT serves a function similar to that of the Intellifit System described in New York Ruling Letter L84425, dated May 18, 2005.
The applicable subheading for the ZOZOSUIT 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 0.8% 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 Evan Conceicao at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division