The tariff classification of a package dimensioning and scale device from China

N353708 September 19, 2025 CLA-2-90:OT:RR:NC:N1:105 CATEGORY: Classification TARIFF NO.: 9031.49.9000; 9903.01.24; 9903.01.25; 9903.88.01 Benjamin Lee Lee Customs Broker LLC 10042 Palo Alto Street Rancho Cucamonga, CA 91730 RE: The tariff classification of a package dimensioning and scale device from China Dear Mr. Lee: In your letter dated September 13, 2025, on behalf of your client, DNA Motor Inc., you requested a tariff classification ruling. Descriptive literature was provided for our review. The article under consideration is described as the DWS M600-D, which is a multifunctional electronic measuring device designed to automate logistics and warehouse processing. The machine integrates three primary functions into a single unit. The first is a high-precision dimensioning device that uses optical and laser sensors to capture the length, width, and height of parcels or packages. The second feature is the integrated barcode reader, which is used to scan and record barcodes (1D/2D) to associate dimensional and weight data with specific shipments or inventory. The third item is the digital scale platform that provides weight measurements of parcels placed on it. Additionally, there is an integrated 12MP camera that can take a picture of a package associated with the measurements. The device is typically installed in distribution centers, express delivery hubs, and warehouse operations to improve efficiency in package processing. It is operated electrically, with an onboard interface and data output that can be integrated into enterprise warehouse management systems. The device also comes with a computer screen, mouse, industrial computer, and a trolley to move the item around. This merchandise is considered to be a composite machine, which uses optical and laser sensors to determine the dimensions of a package, the scale to obtain the weight of a package, and the barcode reader to identify and link the package data. Since, a principal function cannot be determined for this composite machine, General Explanatory Note (VI) to Section XVI directs us to apply General Interpretative Rule 3 (c). General Interpretative Rule 3 (c) provides that goods shall be classified under the heading which occurs last in numerical order among those (heading 9031, optical measuring, heading 8423, scale, and Chapter 85, barcode scanner) which equally merit consideration. Based on the above, classification of this device will be under heading 9031, Harmonized Tariff Schedule of the United States (HTSUS). Accordingly, the applicable subheading for the DWS M600-D will be 9031.49.9000, 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 optical instruments and appliances: Other: Other.” The general rate of duty will be free. Effective March 4, 2025, pursuant to U.S. Note 2(u) to Subchapter III, Chapter 99, all products of China and Hong Kong as provided by heading 9903.01.24, HTSUS, other than products classifiable under headings 9903.01.21, 9903.01.22, and 9903.01.23, HTSUS, will be subject to an additional 20 percent ad valorem rate of duty. At the time of entry, you must report the applicable Chapter 99 heading, i.e., 9903.01.24, in addition to subheading 9031.49.9000, HTSUS, listed above. 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 China, Hong Kong, and Macau will be subject to an additional ad valorem rate of duty of 10 percent. 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 9031.49.9000, HTSUS, listed above. Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 9031.49.9000, 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 9903.88.01 in addition to subheading 9031.49.9000, 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, including information on exclusions and their effective dates, 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. 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 Jason Christie at jason.m.christie@cbp.dhs.gov. Sincerely, (for) Denise Faingar Acting Director National Commodity Specialist Division