CLA-2-85:OT:RR:NC:N2:220
Jennifer Diaz
Diaz Trade Law
12700 Biscayne Boulevard, Suite 401
North Miami, FL 33181
RE: The tariff classification of an expansion module from China
Dear Ms. Diaz:
In your letter dated October 5, 2022, you requested a tariff classification ruling on behalf of your client, K-Rain Manufacturing Corporation.
The merchandise under consideration is identified as the ProEX 2.0 4 Zone Expansion Module, Part Number 3205, which is described a printed circuit board assembly (PCBA) mounted within a plastic enclosure. The PCBA incorporates four power relays, a terminal block, and a ribbon cable extending from the module cover. In use, the subject Expansion Module distributes 24 V power to increase the number of zones in an electrically controlled irrigation system.
In your request, you suggest the Expansion Module is classifiable under subheading 8537.10.9170, Harmonized Tariff Schedule of the United States (HTSUS). We agree.
The applicable subheading for the ProEX 2.0 4 Zone Expansion Module, Part Number 3205, will be 8537.10.9170, HTSUS, which provides for “Boards, panels, consoles, desks, cabinets and other bases, equipped with two or more apparatus of 8535 or 8536, for electric control or the distribution of electricity…: For a voltage not exceeding 1,000 V: Other: Other: Other”. The general rate of duty will be 2.7 percent ad valorem.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 8537.10.9170, 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., 9903.88.03, in addition to subheading 8537.10.9170, 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, including information on exclusions and their effective dates, you may refer to the relevant parts of the USTR and CBP websites, which are available at the following addresses:
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 Karl Moosbrugger at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division