CLA-2-85:OT:RR:NC:N2:209
Tim Schillemans
Prodrive Technologies Inc.
15 University Road
Canton, MA 02021
RE: The tariff classification of a routing/switching module from China
Dear Mr. Schillemans:
In your letter dated November 03, 2020, you requested a tariff classification ruling.
The item concerned is referred to as the ELS61 module. This item consists of a printed circuit board with a variety of electrical components installed, forming a printed circuit board assembly (PCBA). The PCBA is capped off with a protective cover.
The ELS61 module is the functional component of a telemetry module, which is used as a network switching and routing device. As the main or functional component of the telemetry device, the ELS61 module is responsible for providing the switching and routing functionality to the unit.
This module is responsible for routing and switching data between cell towers and connected products. It will be used in a Controller Area Network (CAN). The module will be used to send and receive data between electronic apparatus in a truck and the internet.
The applicable subheading for the ELS61 module will be 8517.62.0020, HTSUS, which provides for “Telephone sets…; other apparatus for the transmission or reception of voice, images or other data…: Other apparatus for transmission or reception…: Machines for the reception, conversion, and transmission or regeneration of voice, images or other data, including switching and routing apparatus: Switching and routing apparatus.” The general rate of duty will be Free.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 8517.62.0020, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.04, in addition to subheading 8517.62.0020, HTSUS, listed above.
The HTSUS is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, you may refer to the relevant parts of the USTR and CBP websites, which are available at https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and https://www.cbp.gov/trade/remedies/301-certain-products-china, respectively.
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 Steven Pollichino at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division