The tariff classification of an automobile power line communication module from South Korea

N352297 August 20, 2025 CLA-2-85:OT:RR:NC:N2:209 CATEGORY: Classification TARIFF NO.: 8517.62.0090, 9903.01.32 Young Man Lee Mobis Parts America. LLC 10550 Talbert Ave. Fountain Valley, CA 92708 RE: The tariff classification of an automobile power line communication module from South Korea Dear Mr. Lee: In your letter dated August 12, 2025, you requested a tariff classification ruling. The item concerned is referred to as a power line communication module, Model Number: 91687-Q4010. This product is installed in the center of an electric vehicle’s cowl crossbar, and is composed of a printed circuit board assembly (PCBA) within a plastic housing. The PCBA incorporates various electronic elements/components (i.e. resistor, inductor, choke coil, flash memory, CAN transceiver, PHY chip, M icrocontroller, crystal, etc.). This module is used to facilitate the transmission of battery charging status within an automobile. When charging the battery, this device converts the power line communication signal (PLC), from the rapid charger, to the controller area network signal (CAN) of the vehicle, and it converts the CAN signal to the PLC signal. This module allows for the data exchange of the various charging statuses (i.e., voltage and current, remaining charge, charging time, etc.) between the external charger and the vehicle’s battery management system. In your request, you suggest the correct classification for the subject device is under subheading 8543.70.9860, Harmonized Tariff Schedule of the United States (HTSUS). We disagree. In order for a device to be classified within heading 8543, HTSUS, it must provide an electrical function that is not more specifically provided for elsewhere within the Chapter. In our view, the principal function of this device is to convert and transmit certain signals within a vehicle. As this is a function more accurately described elsewhere, heading 8543, HTSUS, is not applicable. The applicable subheading for the power line communication module, Model Number: 91687-Q4010 will be 8517.62.0090, HTSUS, which provides for “Telephone sets, including smartphones and other telephones for cellular networks or for other wireless networks; other apparatus for the 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)…: 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. 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 of South Korea will be subject to an additional ad valorem rate of duty of 15 percent. Your product falls within an excepted subheading. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.01.32, in addition to subheading 8517.62.0090, 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 Steven Pollichino at steven.pollichino@cbp.dhs.gov. Sincerely, (for) James Forkan Acting Director National Commodity Specialist Division