The tariff classification of a wireless speaker system from China

N358304 February 17, 2026 CLA-2-85:OT:RR:NC:N2:209 CATEGORY: Classification TARIFF NO.: 8518.22.0000 Jamal Ayache Serene Group, Inc. 3401 E University Dr., Suite 206 Denton, TX 76208 RE: The tariff classification of a wireless speaker system from China Dear Mr. Ayache: In your letter dated January 28, 2026, you requested a tariff classification ruling. The item(s) concerned is referred to as the Sereonic Wireless TV Assistive Speaker (Model #’s: BT-200Pro Series and BT-300Pro Series). Both models of speaker system consist of a wireless transmitter/charging base that connects to a television set, and an amplified wireless speaker module that can be placed up to 100 ft from the transmitter. The speaker modules incorporate two speakers, a volume control dial, a three-position tone selector switch (low, med, high), an audio port and a headphone jack. The transmitter/charger module incorporates a charging dock, a pairing button (to wirelessly connect to speaker), a power port and audio input ports. The applicable subheading for the Sereonic Wireless TV Assistive Speaker (Model #’s: BT-200Pro Series and BT-300Pro Series) will be 8518.22.00 00, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Microphones and stands therefor; loudspeakers, whether or not mounted in their enclosures; headphones and earphones, whether or not combined with a microphone, and sets consisting of a microphone and one or more loudspeakers; audio-frequency electric amplifiers; electric sound amplifier sets; parts thereof: Loudspeakers, whether or not mounted in their enclosures: Multiple loudspeakers, mounted in the same enclosure”. The general rate of duty will be Free. In your submission you requested consideration of a secondary classification under 9817.00.96, HTSUS, which applies to articles and parts of articles specifically designed or adapted for the use or benefit of the permanently or chronically physically or mentally handicapped. Subheading 9817.00.96, HTSUS, covers: “Articles specially designed or adapted for the use or benefit of the blind or other physically or mentally handicapped persons; parts and accessories (except parts and accessories of braces and artificial limb prosthetics) that are specially designed or adapted for use in the foregoing articles . . . Other.” The term “blind or other physically or mentally handicapped persons” includes “any person suffering from a permanent or chronic physical or mental impairment which substantially limits one or more major life activities, such as caring for one’s self, performing manual tasks, walking, seeing, hearing, speaking, breathing, learning, or working.” U.S. Note 4(a), Subchapter XVII, Chapter 98, HTSUS. Subheading 9817.00.96, HTSUS, excludes “(i) articles for acute or transient disability; (ii) spectacles, dentures, and cosmetic articles for individuals not substantially disabled; (iii) therapeutic and diagnostic articles; or, (iv) medicine or drugs.” U.S. Note 4(b), Subchapter XVII, Chapter 98, HTSUS. In Sigvaris, Inc. v. United States, 227 F. Supp 3d 1327, 1336 (Ct. Int’l Trade 2017), aff’d, 899 F.3d 1308 (Fed. Cir. 2018), the U.S. Court of International Trade (CIT) explained that “specially” means “to an extent greater than in other cases or towards others” and “designed” means something that is “done, performed, or made with purpose and intent often despite an appearance of being accidental, spontaneous, or natural.” We must first evaluate “for whose, if anyone’s, use and benefit is the article specially designed,” and then, whether “those persons [are] physically handicapped [].” Sigvaris, 899 F.3d at 1314. The Court of Appeals for the Federal Circuit (CAFC) clarified in Sigvaris, 899 F.3d at 1314-15 that to be “specially designed,” the merchandise “must be intended for the use or benefit of a specific class of persons to an extent greater than for the use or benefit of others” and adopted the five factors used by U.S. Customs and Border Protection (CBP): 1. The physical properties of the article itself (i.e., whether the article is easily distinguishable by properties of the design, form, and the corresponding use specific to this unique design, from articles useful to non-handicapped persons). 2. Whether any characteristics are present that create a substantial probability of use by the chronically handicapped so that the article is easily distinguishable from articles useful to the general public and any use thereof by the general public is so improbable that it would be fugitive. 3. Whether articles are imported by manufacturers or distributors recognized or proven to be involved in this class or kind of articles for the handicapped. 4. Whether the articles are sold in specialty stores which serve handicapped individuals. 5. Whether the condition of the articles at the time of importation indicates that these articles are for the handicapped. The primary hardware adaptation for both models of this speaker system is the “Voice Clarifying Tone Control”. This dedicated circuitry selectively boosts high-frequency speech consonants (1kHz–5kHz) and low-frequency speech consonants (100Hz – 500Hz) to compensate for sensorineural loss patterns common in seniors, distinct from standard entertainment audio profiles. In HQ 950772 and HQ 951004, CBP considered amplified telephones. In both instances the request for use of the special provision under subheading 9817.00.96, HTSUS, was denied. CBP explained that the degree of additional features for the benefit of the handicapped was minimal, as such they failed to alter the basic character of a conventional phone. It is CBP’s opinion that the amplified speakers, subject to this ruling, are similar to the merchandise found in HQ 950772 and HQ 951004, in that their design, modification, or adaptation is not significant enough, as to clearly render the article for use by handicapped persons. The basic character of a conventional amplified speaker is retained. Additionally, as the items are sold online to the general public, and in part advertised as being useful in competing with outside noise distractions, they provide a useful function to non-handicapped persons as well. Based on the information supplied, the two models of amplified speakers in question, Model #’s: BT-200Pro Series and BT-300Pro Series, do not satisfy the 5 factors set out by CBP. As a result, it is the opinion of this office that a secondary classification in subheading 9817.00.96, HTSUS, will not apply. The 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/. This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the classification stated above, the merchandise covered by this ruling may also need to be reported with either the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions covering exceptions to such tariffs. For further information to assist with the importation process, please refer to the frequently updated Cargo Systems Messaging Service (CSMS) messages at https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and Frequently Asked Questions on the Trade Remedy/IEEPA page at https://www.cbp.gov/trade/programs-administration/trade-remedies/IEEPA-FAQ. 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 Designated Official Performing the Duties of the Division Director National Commodity Specialist Division