The tariff classification of an analog digital converter from Japan

N351244 July 29, 2025 CLA-2-85:OT:RR:NC:N2:212 CATEGORY: Classification TARIFF NO.: 8543.70.9860; 9903.01.25 Shinji Azuma Amuza Inc 10060 Carroll Canyon Rd, Suite 100 San Diego, CA 92131 RE: The tariff classification of an analog digital converter from Japan Dear Mr. Azuma: In your letter dated July 11, 2025, you requested a tariff classification ruling. The merchandise under consideration is identified as the Colibrick Analog/Digital (A/D) converter, which you state is specifically designed for use within a gas chromatography system. The subject device is presented as a small black box with various LED status lights on one side and a USB and specialized connection point designed to accept signals from the chromatography machine on the other. We note that the chromatography device is not at issue with this request. In use, the device is used in scientific applications by accepting results from the chromatography machine in analog form and converting them to digital. This digital signal is then sent through the USB connection to a PC so that it can be analyzed. The applicable subheading for the Colibrick A/D converter will be 8543.70.9860, Harmonized Tariff Schedule of the United States (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