The tariff classification of a UV sanitizer system from South Korea

N312196 June 12, 2020 CLA-2-85:OT:RR:NC:N2:212 CATEGORY: Classification TARIFF NO.: 8543.70.9960 Jennifer Ho AJH Elite Customs Brokerage 24328 South Vermont Avenue, Number 230 Harbor City, CA 90710 RE: The tariff classification of a UV sanitizer system from South Korea Dear Ms. Ho: In your letter dated June 2, 2020, you requested a tariff classification ruling on behalf of your client, Opus International, LLC. The merchandise under consideration is identified as the Model E WeClean Escalator Handrail Sanitizer System. The system consists of an ultraviolet (UV) light, disinfectant applicator, cleaning roller, and a 7-inch LCD monitor. These items are contained within a metal housing specifically shaped to fit onto the handrail of an escalator. The unit can be further expanded to include multiple other features including motion sensors, temperature sensors, and a people counter. In use, the sanitizer system is attached to the handrail on one end of an escalator in order for the handrail to continuously pass through. The system initially sterilizes and disinfects with a liquid spray. Following this, the cleaning roller removes any foreign substances before the UV light sterilizes and kills all bacteria or viruses on the surface. The LCD monitor is used to display a variety of customizable information including real-time public information or required video transmissions. It is our opinion that the subject sanitizer system meets the definition of a composite machine as it consists of two or more articles with functions that are, prima facie, classifiable in different headings. As such, classification is governed by Note 3 to Section 16 of the Harmonized Tariff Schedule of the United States (HTSUS), which states, in pertinent part, that classification is determinant upon the principal function of the good. In reviewing the information presented, it is the opinion of this office that the UV sterilization light imparts the principal function of the system. The applicable subheading for the Model E WeClean Escalator Handrail Sanitizer System will be 8543.70.9960, HTSUS, which provides for “Electrical machines and apparatus, having individual functions, not specified or included elsewhere in this chapter; parts thereof: Other machines and apparatus: Other: Other: Other: Other.” The general 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 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 Luke LePage at luke.lepage@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division