CLA-2-85:OT:RR:NC:N2:212
Alejandro Franco
American Printing House for the Blind
1839 Frankfort Avenue
Louisville, KY 40206
RE: The tariff classification of a coding trainer from China
Dear Mr. Franco:
In your letter dated January 29, 2020, you requested a tariff classification ruling.
The merchandise under consideration, identified as the Code Jumper, is described as an accessible physical coding trainer kit for children who are blind or visually impaired. The kit contains a coding hub and several command pods packaged within a plastic carrying case. The hub is comprised of a plastic housing and features a speaker, play button, stop button, volume dial and four specifically designed input ports. The hub is battery powered. There are five different types of command pods described as the play pod, pause pod, loop pod, selection pod, and merge pod. Each is comprised of a connecting wire, input ports, and different shaped dials.
In use, the hub is connected via Bluetooth to a personal computer or smart device that is loaded with the Code Jumper application. The command pods are then physically connected to the hub, via the incorporated wires, in order to represent lines of computer code. The dials on each pod are shaped differently in order to allow the visually impaired student to feel the difference in the specific commands. When the physical coding sequence is in the desired order, the hub will play songs, stories, or other sounds. The application allows for pre-programmed songs or the students can make their own by sequencing the pods to control duration and pitch of the sounds.
The applicable subheading for the Code Jumper will be 8543.70.9301, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electrical machines and apparatus, having individual functions, not specified elsewhere in this chapter; parts thereof: Other machines and apparatus: Other: Other: Portable interactive electronic education devices primarily designed for children.” The general rate of duty will be free.
In your submission, you request consideration of a secondary classification for the subject coding trainer under 9817.00.94, HTSUS, which applies to as articles specially designed or adapted for the use or benefit of the blind. Chapter 98, Subchapter XVII, U.S. Note 4(a), HTSUS, defines the term “blind or other physically or mentally handicapped persons” as including “any person suffering from a permanent or chronic physical or mental impairment which substantially limits one or more major life activities, such as caring for one's self, performing manual tasks, walking, seeing, hearing, speaking breathing, learning, or working.”
You state that the Code Jumper is specifically designed for children that are blind or visually impaired in order to learn computer coding. Based on the information provided, the command pods contain tactile features that are designed to allow blind and visually impaired students to easily identify their functions. Further, the result of a successful code produces an audio response, which allows it to be easily understood by those with visual disabilities. As such, a secondary classification will apply to the Code Jumper under 9817.00.94, HTSUS, which affords free duty treatment aside from any additional duties and/or applicable fees upon importation into the United States.
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 the 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 Luke LePage at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division