CLA-2-84:OT:RR:NC:N1:105
David Cho
D & B Customs LLC
3700 Crestwood Parkway NW STE 815 Duluth, GA 30096
RE: The tariff classification of a disinfection service robot from South Korea
Dear Mr. Cho:
In your letter dated August 21, 2023, on behalf of your client, Hyundai Robotics, you requested a tariff classification ruling.
The item under consideration is described as the Hyundai D1 Robot, which is a self-driving disinfection service robot based on 2D LiDAR (light detection and ranging). LiDAR is a technology that targets an object with a laser and measures the time that passes until the reflected light returns to the receiver. The LiDAR sensor on the D1 is capable of generating a 2-dimensional image with spatial and depth data for detecting, measuring, localizing and tracking objects. The robot is composed of a UV-C LED for floor sterilization and a disinfection module for air purification. The robot also has eight sensors mounted throughout the device including 3 fine particle sensors, an ozone sensor, a CO2 sensor, a TVOC (organic compounds) sensor, a temperature sensor and a humidity sensor. The disinfection module uses plasma sterilization for virus removal and a circular triple filter to trap fine particles. The D1 can be utilized as a stationary air purifier as well as an automated mobile air purifier and sterilizer. Additionally, the robot can be programmed to operate automatically at scheduled disinfection times. The D1 has a controller, motor, battery, LiDAR, disinfection module, and an upper application module that includes a 3D camera and touch display. It is imported with the main robot body, a power cable, a wired charging cable, and a charging station. The device measures 58cm by 58cm by 129cm and weighs 74kg.
The applicable subheading for the Hyundai D1 Robot will be 8421.39.0115, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Centrifuges, including centrifugal dryers; filtering or purifying machinery and apparatus, for liquids or gases; parts thereof: Filtering or purifying machinery and apparatus for gases: Other: Dust collection and air purification equipment: Other.” The general rate of duty will be free.
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 at https://hts.usitc.gov/current.
The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP.
This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection 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, please contact National Import Specialist Jason Christie at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division