CLA-2-84:OT:RR:NC:N2:220
Carl Mertz
TP-Link USA Corp
145 South State College Blvd Suite 400
Brea, CA 92821
RE: The tariff classification of USB Hubs from China
Dear Mr. Mertz:
In your letter dated October 15, 2018 you requested a tariff classification ruling.
There are three items under consideration which are identified as USB (universal serial bus) Hubs, Model Numbers UH720, UH400, and UC430. Based on the information provided, each of the subject USB Hubs are self-contained and are connected directly to a personal computer (PC) to facilitate data transfer from various peripherals to the connected PC. The USB Hubs also provide device charging, however we are of the opinion that this is a subsidiary feature and not the principal function of the units.
The UH720 USB Hub is described as a standalone interconnection unit that measures 6.5 x 2.6 x 0.7 inches and connects to a user’s PC via the USB 3.0 Micro socket located on the rear of the device. On the front of the device are seven standard USB 3.0 ports that allow users to connect a device of their choosing, such as a memory drive or a printer. On one side of the UH720 USB Hub are two USB 3.0 Smart Charging Ports where users can connect their mobile device for charging and interfacing with the PC.
The UH400 USB Hub is a compact standalone interconnection unit that measures 2.8 x 2.8 x 0.7 inches and connects to a user’s PC via the a built-in “fold away” USB 3.0 cable. On the front and side of the device are two standard USB 3.0 ports, for a total of four ports, which allow users to connect a device of their choosing, such as a memory drive or a printer.
The UC430 USB Hub is portable standalone interconnection unit that measures 1.97 x 0.57 x 2.89 inches and connects to a user’s PC via the built-in USB 3.0 cable. On the front of the device are three standard USB 3.0 ports and one USB-C 3.0 Smart Charging Port that allow users to connect a device of their choosing, such as a memory drive, a smart device, or a printer.
The applicable subheading for the USB Hubs, Model Numbers UH720, UH400, and UC430 will be 8471.80.1000, Harmonized Tariff Schedule of the United States, (HTSUS), which provides for “Automatic data processing machines and units thereof…: Other units of automatic data processing machines: Control or adapter units.” The rate of duty will be Free.
Effective July 6, 2018, the Office of the United States Trade Representative (USTR) imposed an additional tariff on certain products of China classified in the subheadings enumerated in Section XXII, Chapter 99, Subchapter III U.S. Note 20(b), HTSUS. The USTR imposed additional tariffs, effective August 23, 2018, on products classified under the subheadings enumerated in Section XXII, Chapter 99, Subchapter III U.S. Note 20(d), HTSUS. Subsequently, the USTR imposed further tariffs, effective September 24, 2018, on products classified under the subheadings enumerated in Section XXII, Chapter 99, Subchapter III U.S. Note 20(f) and U.S. Note 20(g), HTSUS. For additional information, please see the relevant Federal Register notices dated June 20, 2018 (83 F.R. 28710), August 16, 2018 (83 F.R. 40823), and September 21, 2018 (83 F.R. 47974). Products of China that are provided for in subheading 9903.88.01, 9903.88.02, 9903.88.03, or 9903.88.04 and classified in one of the subheadings enumerated in U.S. Note 20(b), U.S. Note 20(d), U.S. Note 20(f) or U.S. Note 20(g) to subchapter III shall continue to be subject to antidumping, countervailing, or other duties, fees and charges that apply to such products, as well as to those imposed by the aforementioned Chapter 99 subheadings.
Products of China classified under subheading 8471.80.1000, HTSUS, unless specifically excluded, are subject to the additional 10 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.03, in addition to subheading 8471.80.1000, HTSUS, listed above.
The tariff is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Notice cited above and the applicable Chapter 99 subheading.
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