The tariff classification of a Healthy Home Coach from China

N278606 September 15, 2016 CLA-2-90:OT:RR:NC:N1:405 CATEGORY: Classification TARIFF NO.: 9031.80.8085 Miaomiao Li Netatmo 93 Rue Nationale 92100 Boulogne Billancourt France RE: The tariff classification of a Healthy Home Coach from China Dear Ms. Li: In your letter dated August 9, 2016, you requested a tariff classification ruling. The merchandise at issue is identified as the Netatmo Healthy Home Coach. The product, which is cylindrical in shape with an aluminum exterior, is marketed as a device designed to monitor the indoor comfort of a room. The Home Coach features four built-in sensors that enable it to take measurements of a room’s temperature, humidity, carbon dioxide levels, and noise level. The device, which connects to a household’s WiFi network, collects the measurements in question and transmits them to Netatmo’s servers. Users can review the measurement data in real time on their smartphones by means of a downloadable app. The Home Coach determines when an indoor environment is considered “healthy” based on the measurements it takes of the four abovementioned variables. If an environment is deemed “unhealthy” (perhaps due to a high temperature or noise level), a light on the body of the Home Coach will glow red and the app will provide advice on how to improve the environment (e.g., open a window, humidify the room, etc.). The Healthy Home Coach’s inbuilt sensors enable it to simultaneously measure four separate variables, and determine if they fall within parameters that are deemed “healthy.” In this respect the Healthy Home Coach serves a function akin to that of the IncuTest described in New York Ruling Letter N134318, dated December 14, 2010. The product covered by that ruling measured the temperature, air flow, humidity, and sound levels in an infant incubator to determine whether said incubator was operating within proper specifications. The Healthy Home Coach, while intended to be used in an enclosed space somewhat larger than that of an infant’s incubator, operates in a similar manner. The applicable subheading for the Healthy Home Coach will be 9031.80.8085, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Measuring or checking instruments, appliances and machines, not specified or included elsewhere in this chapter; profile projectors; parts and accessories thereof: Other instruments, appliances and machines: Other: Other. The rate of duty will be 1.2% 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 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 Evan Conceicao at evan.m.conceicao@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division