CLA-2-85:OT:RR:NC:N2:212

Peter Ruggiero
Panzer Performance
3346 Current Avenue
Winter Garden, FL 34787

RE: The tariff classification of a magnetic sensor board from China

Dear Mr. Ruggiero:

In your letter dated March 26, 2022, you requested a tariff classification ruling.

The merchandise under consideration is described as a magnetic sensor board, which you state is used as a sensor in an air flow meter. The subject board is comprised of a magnetic sensor and microcontroller soldered onto a printed circuit board (PCB) along with other electrical components. After importation, jumper connection points are added to the board and software is programmed. The board is then combined with a rotating magnet and placed within the air intake system of a vehicle.

When air passes through the air intake system of the vehicle, it turns the rotating magnet attached to the board. The magnetic sensor on the board then senses how far the flap has turned and generates an electrical signal that correlates to the rotational angle of the magnet. This allows the vehicle to guage how much air the vehicle is taking in at a given time. In our view, this board functions as a transducer, as it converts a non-electrical (magnetic) signal to an electrical one for further processing.

The applicable subheading for the magnetic sensor board will be 8543.70.4500, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electrical machines and apparatus, having individual functions, not specified or included elsewhere in this chapter; parts thereof: Other machines and apparatus: Electric synchros and transducers; flight data recorders; defrosters and demisters with electric resistors for aircraft: Other.” The general rate of duty will be 2.6% ad valorem.

Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 8543.70.4500, 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., 9903.88.02, in addition to subheading 8543.70.4500, 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 Section 301 trade remedy, 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 https://www.cbp.gov/trade/remedies/301-certain-products-china

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