The tariff classification of a Center Information Display Unit from Vietnam

N260022 December 23, 2014 CLA-2-85:OT:RR:NC:N1:112 CATEGORY: Classification TARIFF NO.: 8543.70.9650 Sarah M. Cho Customs Compliance Senior Manager LG Electronics USA Inc. 1000 Sylvan Avenue Englewood Cliffs, NJ 07632 RE: The tariff classification of a Center Information Display Unit from Vietnam Dear Ms. Cho: In your letter dated December 8, 2014 you requested a tariff classification ruling. The merchandise in question is referred to as the Center Information Display Unit. This interactive liquid crystal display (LCD) unit is intended to be installed inside a vehicle dashboard for the purpose of providing the occupants with control of on-board audio functions, navigation, cellular communications, and rear back-up camera operations. The 7 inch diagonal display has a resolution 800 X 480, a light emitting diode backlight, and a control area utilizing a capacitive touchscreen for menu and audio operations. The Center Information Display connects to a vehicle’s digital audio controller through a low voltage serial communication cable. Based on the documentation you provided, there are three functional areas on the device where information is to be displayed. The first area occupies the left column and provides for power, menu selection, volume, and home buttons. The second area, across the top of the display, indicates vehicle climate conditions, radio selection, Wi-Fi status, and a clock. And lastly, in the main area of the display is the menu where the user can select navigation functions, phone, audio, camera, or access system settings. This unit is contained in a black plastic housing with metal brackets to secure its installation into the center of the vehicle’s dashboard. You suggested a tariff classification of 8528.59.2500, Harmonized Tariff Schedule of the United States (HTSUS), which provides, in pertinent part, for “Other monitors: Other: With a video display diagonal not exceeding 34.29 cm”. However, the Center Information Display Unit is a wired controller incorporating an LCD touchscreen that displays navigation, video, rear camera images and other vehicle information, as well as allowing the user to interact and control in-vehicle systems, which takes the principal function beyond that of only a monitor. Therefore, classification under 8528.59.2500, HTSUS, is not appropriate. The applicable subheading for the Center Information Display Unit, Model # CID07LT-HO, will be 8543.70.9650, HTSUS, which provides for “Electrical machines and apparatus…: Other machines and apparatus: Other: Other: Other: Other”. The general rate of duty will be 2.6 percent ad valorem. 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 World Wide Web at http://www.usitc.gov/tata/hts/. 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 karl.moosbrugger@cbp.dhs.gov. Sincerely, Gwenn Klein Kirschner Director National Commodity Specialist Division