The tariff classification of tracking/monitoring wristband, hub and satellite units from China

N316541 January 13, 2021 CLA-2-85:OT:RR:NC:N2:209 CATEGORY: Classification TARIFF NO.: 9031.80.8085, 8517.62.0090 Mr. Jonas Klingenstierna Logac AB Isafjordsgatan 39B Stockholm, 16440 Sweden RE: The tariff classification of tracking/monitoring wristband, hub and satellite units from China Dear Mr. Klingenstierna: In your letter dated December 17, 2021, you requested a tariff classification ruling on behalf of your client, Camanio Care Inc. The items concerned are components that make up the Nectarine Remote - Tracking solution. The individual components include a wrist band, a satellite unit, and a hub unit. The three components (wristband, satellite, and hub) are used/installed in a user’s home. The purpose of this system is to gather user activity/movement data and user location data. The data generated/gathered is forwarded via the satellite and hub to the Nectarine cloud/Nectarine SmartApp. Voice communication can also be established via microphones, in the wristband, satellite and hub, and speakers in the satellite and hub (No speaker in the wristband). The wristband, satellite and hub are all sold as individual products. The communication between wristband, satellite and hub is accomplished via Bluetooth technology. Communication between the Hub and the Nectarine Cloud is accomplished using Wi-Fi technology and a standard 2.4 Ghz or 5 Ghz Wi-Fi router or Wi-Fi hub. The wristband is a multifunctional electronic wearable device, worn on a person’s wrist. Its primary function is to gather data about the movement of the wearer, and transmit it over Bluetooth via the Nectarine hub and satellite to the cloud, where AI algorithms are run to help discover changes in the wearer’s sleep and daily activity patterns, which can then be used by professionals if necessary. The wristband contains various sensors including an accelerometer, microphone, barometric (air pressure) sensor, and a magnetometer. It has a programmable button that can be used for different purposes, including calling for help, and features an LED for visual feedback. Communication between wristband and the satellite or hub is accomplished via Bluetooth technology. The wristband weighs 15 grams and includes a strap of silicone and an encapsulated electronic module. The electronic device is powered by an inbuilt Lithium polymer battery. The satellite is a small multifunctional home electrical radio network device that would be plugged into any regular 120-volt wall power socket. The satellite’s primary function is to increase the Bluetooth coverage of the Nectarine Remote - Tracking network. It works together with the hub to achieve this by building out a Bluetooth network through relaying or meshing. It boosts and improves the wireless coverage range of the wristband in the home. It receives end user data from the wristband and relays the data to the Hub. Its secondary function is to enable positioning of the wristband. The satellite positions the wristband in the network and transmits the position-data to the hub. The satellite also includes call capability via inbuilt microphone and speaker used in the event something happens to the wearer of the wristband. Communication from the satellite to the wristband and the hub is over Bluetooth. The weight of the satellite is 128 grams, and it has a plastic casing with three inbuilt LEDs for visual. It is powered via 120 volt regular socket and has an inbuilt battery for power backup. The hub is a small multifunctional electrical radio network device plugged into a regular wall power socket (120Volt). Its primary function is to receive end user data from the wristband or the satellite and relay the data to a standard Wi-Fi router. The hub also enables positioning and location services relaying the position-data to the Wi-Fi router. The hub also includes call capability via inbuilt microphone and speaker used in the event something happens to the wearer of the wristband. Communication from the hub to the wristband and satellite is over Bluetooth. Communication with the Wi-Fi router is via Wi-Fi technology. The weight of the hub is 135 grams, and it has a plastic casing with three inbuilt LEDs for visual. It is powered via 120 volt regular socket and has an inbuilt Lithium polymer battery as power backup. The applicable subheading for the wristband 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 general rate of duty will be free. Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 9031.80.8085, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.01, in addition to subheading 9031.80.8085, HTSUS, listed above. The applicable subheading for the satellite unit and the hub unit will be 8517.62.0090, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Telephone sets, including telephones for cellular networks or for other wireless networks; other apparatus for the transmission or reception of voice, images or other data…: Other apparatus for transmission or reception of voice, images or other data, including apparatus for communication in a wired or wireless network (such as a local or wide area network): Machines for the reception, conversion and transmission or regeneration of voice, images or other data, including switching and routing apparatus: Other.” The general rate of duty will be Free. Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 8517.62.0090, HTSUS, unless specifically excluded, are subject to an additional 7.5 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.15, in addition to subheading 8517.62.0090, HTSUS, listed above. The HTSUS is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, you may refer to the relevant parts of the USTR and CBP websites, which are available at https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and https://www.cbp.gov/trade/remedies/301-certain-products-china, respectively. 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 Steven Pollichino at steven.pollichino@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division