The tariff classification of a personal assistant robot from Vietnam

N350114 July 3, 2025 CLA-2-85:OT:RR:NC:N2:212 CATEGORY: Classification TARIFF NO.: 8543.70.9860 Adam Srebnik Sandler, Travis & Rosenberg, P.A. 5835 Waterford District Drive, Suite 200 Miami, FL 33126 RE: The tariff classification of a personal assistant robot from Vietnam Dear Mr. Srebnik: In your letter dated June 11, 2025, you requested a tariff classification ruling on behalf of your client, Samsung Electronics America, Inc. The merchandise under consideration is identified as the Ballie robot, which is further described as an advanced, artificial intelligence (AI) driven personal assistant. The subject robot is a small, spherical device that incorporates wheels, allowing it to move around a room. The device further incorporates various cameras, a projector, Infrared (IR) sensors, a microphone, speaker, LiDar, as well as various environmental sensors. We note that the only mechanical properties of the device are the wheels, and it does not incorporate any arms or other articulating features. In use, the robot acts as a rolling companion and AI personal assistant for home automation, allowing users to control various smart appliances, lights and other connected devices throughout the home. The robot connects to the internet and other devices throughout the home via WiFi and Bluetooth. The user can verbally communicate with the robot, speaking commands, to which the device will respond by using a large language model search. The cameras and projector allow for the device to monitor the surrounding area as well as to project information including streaming videos and other content on any wall throughout the home. In your request, you suggest that the correct classification for the subject robot is 8543.70.9860, Harmonized Tariff Schedule of the United States (HTSUS). We agree. The applicable subheading for the Ballie robot will be 8543.70.9860, 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. Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time products from all countries will be subject to an additional 10 percent ad valorem rate of duty. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.01.25, in addition to subheading 8543.70.9860, HTSUS, listed above. The tariffs and additional duties cited above are current as of this ruling’s issuance. 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 at https://hts.usitc.gov/. The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection 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, please contact National Import Specialist Luke LePage at luke.lepage@cbp.dhs.gov. Sincerely, (for) James Forkan Acting Director National Commodity Specialist Division