RE: The tariff classification of a valve sensor from Belgium

U.S. Department of Homeland Security U.S. Customs and Border Protection National Commodity Specialist Division One World Trade Center, Suite 51.201 New York, NY 10007 U.S. Customs and Border Protection N365958 October 23, 2026 CLA-2-90:OT:RR:NC:N1:105 CATEGORY: Classification TARIFF NO.: 9031.80.8085 Adelina Soiu Aloxy NV Sint-Pietersvliet 7 Antwerpen 2000 Belgium RE: The tariff classification of a valve sensor from Belgium Dear Ms. Soiu: In your letter dated October 12, 2026, you requested a tariff classification ruling. Descriptive literature was provided for our review. The item under consideration is described as the Aloxy Pulse (also known as the Aloxy Valve Sensor), which is a wireless Industrial Internet-of-Things (IIoT) valve monitoring sensor. The device is a self-contained, battery-operated electronic device designed to track and transmit the real-time position of manual valves (such as handwheels and levers) in hazardous industrial environments. To achieve universal, non-intrusive mounting without the need for physical valve modifications or specialized mechanical linkages, the device operates by utilizing an integrated internal suite of three inertial Micro-Electromechanical Systems (MEMS) sensors. The primary sensing matrix consists of a 3-axis MEMS accelerometer, a 3-axis MEMS gyroscope, and a 3-axis MEMS magnetometer, which collectively capture comprehensive spatial, rotational, and directional data. Specifically, the accelerometer measures linear acceleration and gravitational forces along three orthogonal axes to establish tilt angles and vibration thresholds, enabling the device to detect when a valve handle is set in motion or experiencing high process vibrations. The gyroscope functions by tracking angular velocity and changes in pitch, roll, and yaw, registering the dynamic rotation and precise rate of movement as an operator spins a handwheel or shifts a lever. Simultaneously, the magnetometer measures the surrounding magnetic field and directional orientation relative to the Earth’s magnetic north, establishing a stable heading reference that compensates for potential errors or drift in the inertial data. The Aloxy Pulse functions by processing raw data from these multiple sensor arrays directly via its onboard microcontroller. When clamped onto a manual valve component, a proprietary algorithm converts the recorded physical movement, angular changes, and directional orientation into an exact positional percentage, allowing the device to register not only fully open and fully closed states but intermediate percentages (e.g., 30% open) as well. The sensor remains primarily in a low-power state, capturing heartbeats at predefined intervals or waking instantly to calculate position change upon detecting motion events. Once calculated, the processed position data is transmitted wirelessly via embedded long-range, low-power radio transponders supporting protocols like LoRaWAN or DASH7. This digital payload is relayed through localized gateways back to a centralized control system or the Aloxy IIoT Hub, giving operators continuous oversight of manual asset positions without manual field inspection. In your letter, you suggest the subject article is correctly classified under subheading 8517.62.0020, Harmonized Tariff Schedule of the United States (HTSUS). We disagree. The article in question is a sensor designed to detect the movement of an attached valve and transmit its open/close status utilizing integrated wireless LoRaWAN technology. The principal function of the device is to detect this valve status and relay that information to the user via wireless transmission. In our opinion, the transmission function is entirely dependent upon, and has no function on its own without, the underlying status data generated by the sensor. Accordingly, classification under heading 8517, HTSUS, is precluded since the sensor is used primarily to execute a sensing or detecting function which would be beyond the scope of heading 8517, HTSUS. Furthermore, merchandise classifiable in Chapter 90 is precluded from classification in Chapter 85 by Section XVI by Note 1(m). Accordingly, the applicable subheading for the Aloxy Pulse (also known as the Aloxy Valve Sensor) will be 9031.80.8085, 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 instruments, appliances and machines: 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 Jason Christie at jason.m.christie@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division