The tariff classification of Raspberry Pi components from Great Britain

N285106 April 25, 2017 CLA-2-84:OT:RR:NC:N4:120 CATEGORY: Classification TARIFF NO.: 8473.30.5100; 8543.70.9960 Cathy Spencer Freight Expediters 6920 Engle Rd. Suite II Middleburg Heights, OH 44130 RE: The tariff classification of Raspberry Pi components from Great Britain Dear Ms. Spencer: In your letter dated April 6, 2017 you requested a tariff classification ruling on behalf of your client, International Products Sourcing Group. The samples you submitted for our review will be returned as requested. The merchandise under consideration consists of individually packaged accessory components used exclusively with the Raspberry Pi. Four of the five devices under consideration are identified as a “Hat” or a “pHat.” These acronyms represent the method of affixing the devices and simply represent the term “Hardware attached on top.” The term “pHat” merely identifies a smaller version of the Hat. Generally, Hats and pHats are printed circuit board assemblies (PCBA) that each contain a mounted EEPROM which identifies the device to the Raspberry Pi. You also describe the Raspberry Pi as a credit card-sized, single board, fully functional personal computer (PC) and have provided samples that are used with the Raspberry Pi to perform certain functions. The first item, which is not a Hat or a pHat, is referred to as the “Rainbow Pibow 3” and is described as a set of ten stackable layers of laser-cut cast acrylic sheets used to encase and protect the Raspberry Pi PC. The kit comes with four acrylic screws and nuts that hold the stacked sheets together, which are formed to fit around the PC connectors and ports. The outer layers are etched with identifiers for the various connection types on the PC mainboard. Once assembled around the Raspberry Pi, the Rainbow Pibow 3 forms a distinct enclosure for the PC. In your request, you suggest the Rainbow Pibow 3 is properly classified in subheading 8473.30, Harmonized Tariff Schedule of the United States (HTSUS), as a part or accessory to automatic data processing machines. We agree. The second item is referred to as the “pHat DAC” and is described as a PCBA that is physically mounted to the general purpose input/output (GPIO) interface on the Raspberry Pi. The pHat DAC is a digital to analog converter and allows for the operation of audio speakers or other sound producing devices to be connected to the Raspberry Pi. This PCBA consists of control circuitry, terminals for stereo audio out, a separate line out socket, and is connected to the Raspberry Pi through the GPIO connector. In your request you suggest the pHat DAC is properly classified in subheading 8543.70, HTSUS, as a machine or apparatus having an individual function which is not specified elsewhere in the tariff. We agree. The third item is referred to as the “Unicorn Hat” and is described as a PCBA with an 8x8 matrix of Light Emitting Diodes (LED) that you state are used to provide mood lighting, pixel art, persistence of vision effects, status indications, and “blasting color into your surroundings.” A typical use for the Unicorn Hat is for the hobbyist to learn programming and for entertainment purposes. Similar to other Hats, the Unicorn Hat receives its power directly from the Raspberry Pi through the GPIO connector. In your request, you suggest the Unicorn Hat is properly classified in subheading 8543.70, HTSUS, as a machine or apparatus having an individual function which is not specified elsewhere in the tariff. We agree. The fourth item is referred to as the “Explorer Hat Pro” and is described as a kit containing a 10x17 breadboard and a PCBA which consists of the control circuits, four test points, four capacitive touch pads with LEDs, two multi-point terminal strips, and a GPIO connector which is used to attach the assembly to the Raspberry Pi. The terminal strips provide for numerous buffered 5 VDC inputs and outputs, analog input, and motor control output. The Explorer Hat Pro is used as a prototyping board in small electronics projects. In your request you suggest the Explorer Hat Pro is properly classified in subheading 8543.70, HTSUS, as a machine or apparatus having an individual function which is not specified elsewhere in the tariff. We agree. The last item is referred to as the “Skywriter Hat” and is described as a PCBA consisting of the control circuits, a grid for motion sensing, and a GPIO connector which is used to attach the assembly to the Raspberry Pi. The Skywriter Hat uses electrical near-field 3D sensing to generate positional data and detect common gestures like flicks and taps. In your request you suggest the Skywriter Hat is properly classified in subheading 8543.70, HTSUS, as a machine or apparatus having an individual function which is not specified elsewhere in the tariff. We agree. The applicable subheading for the Rainbow Pibow 3 will be 8473.30.5100, HTSUS, which provides for “Parts and accessories (other than covers, carrying cases and the like) suitable for use solely or principally with machines of headings 8469-8472: Parts and accessories of the machines of heading 8471: Not incorporating a cathode ray tube: Other.” The rate of duty will be Free. The applicable subheading for the pHat DAC, the Unicorn Hat, the Explorer Hat Pro, and the Skywriter Hat will be 8543.70.9960, HTSUS, which provides for “Electrical machines and apparatus, having individual functions, not specified or included elsewhere in this chapter…: Other machines and apparatus: Other: Other: Other: Other.” The rate of duty will be 2.6% 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 Karl Moosbrugger at karl.moosbrugger@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division