The tariff classification of a smart pen device from Malaysia

N359024 March 4, 2026 CLA-2-84:OT:RR:NC:N2:212 CATEGORY: Classification TARIFF NO.: 8471.60.9050 Marc Tuinier Nuwa Labs, Inc. 2 Marina Blvd B300 San Francisco, CA 94123 RE: The tariff classification of a smart pen device from Malaysia Dear Mr. Tuinier: In your letter dated February 20, 2026, you requested a tariff classification ruling. The merchandise under consideration is identified as the Nuwa Pen, which is further described as a handheld smart pen. The subject device is comprised of an internal printed circuit board assembly (PCBA), an intelligent image capture system, and an ink cartridge enclosed within a pen-shaped housing. The device is rechargeable and incorporates Bluetooth connectivity as well as an internal memory. The subject smart pen can be used as a traditional pen, as it will write on any surface and does not need designated paper or other electrical writing surface. The image capture system records the writing strokes and transfers them to a smartphone, tablet or computer that incorporates the necessary application. The application then allows the user to view their written notes, transform the notes into a typed format, and store the notes for later viewing. In your request, you suggest that the correct classification for the subject device should be 8471.90.9000, Harmonized Tariff Schedule of the United States (HTSUS). We note that this proposed classification is not present within the tariff. As such, this will not be the correct classification. However, we agree with the proposed heading and consider the device an input unit for an automatic data processing (ADP) machine. The applicable subheading for the Nuwa Pen will be 8471.60.9050, HTSUS, which provides for “Automatic data processing machines and units thereof…Input or output units, whether or not containing storage units in the same housing: Other: Other: Other.” The general rate of duty will be Free. 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 the Trade Remedies page at https://www.cbp.gov/trade/programs-administration/trade-remedies. 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 Designated Official Performing the Duties of the Division Director National Commodity Specialist Division