N348122

N348122 May 14, 2025 CLA-2-90:OT:RR:NC:N1:105 CATEGORY: Classification TARIFF NO.: 9025.19.8085; 9025.80.1000; 9027.50.4050; 9032.10.0060; 9903.01.24; 9903.01.25; 9903.88.01; 9903.88.02 Farhad Arvin Choovio Inc. 23191 La Cadena Dr., Suite 102 Laguna Hills, CA 92653 RE: The tariff classification of sensors from China Dear Mr. Arvin: In your letter dated April 22, 2025, you requested a tariff classification ruling. Descriptive literature was provided for our review. The items under consideration are a group of long-range wide-area network (LoRaWAN) based environmental sensing devices designed for wireless transmission of environmental data to cloud platforms or LoRaWAN gateways. The devices are used in smart buildings and industrial environments to monitor environmental factors such as air quality, temperature, humidity, carbon dioxide concentration, and light levels. Each product operates autonomously and is powered by battery or USB. The first item under consideration is described as the Milesight AM102, which is an indoor air quality sensor for relative humidity (RH) and temperature. The device uses a small e-ink screen to display the values to the user and stores up to 1,280 historical records. The information is also relayed via a LoRaWAN network. The humidity and temperature sensor uses digital CMOSens technology (micro-electro-mechanical system - MEMS). The device measures 2.68 inches by 2.56 inches by 0.81 inches. The second item under consideration is the Milesight AM308, which is an advanced air quality monitor for total volatile organic compounds (TVOC), fine particulate matter down to 2.5 micrometers or less (PM2.5), fine particulate matter down to 10 micrometers or less (PM10) carbon dioxide (CO2), relative humidity, temperature, light, motion and barometric pressure. The device uses an integrated LED screen to show current values in real-time. The device is also equipped with a traffic light indicator and buzzer to indicate device status and threshold alarms. It can also store up to 18,000 historical records and supports retransmission to prevent data loss. The motion sensor uses passive infrared (PIR), the light sensor utilizes a photodiode, the carbon dioxide sensor uses nondispersive infrared (NDIR), the PM2.5 and PM10 utilize laser scattering, the humidity and temperature sensors use digital CMOSens technology (MEMS), and the TVOC sensor uses metal oxide (MOX) MEMS. The device measures 3.97 inches by 4.49 inches by 0.87 inches. The third item under consideration is the Milesight WT101, which is described as a radiator thermostat to help manage a heating-control system. With a pre-set date period and up to sixteen customized heating plans, it enables the smart management of the heating systems. WT101 has a highly sensitive temperature sensor, which can determine abnormal temperature differences and quickly open or close the associated valve to regulate the temperature. The device utilizes the Milesight LoRaWAN gateway and Milesight IoT Cloud solution, and has an intuitive and direction adjustment LED display to suit different installation environments. It is compatible with the most common radiator valves with optional valve adapters for universal use. The Milesight WT101 measures 2.05 inches by 3.54 inches and is made of stainless steel and plastic. The fourth item under consideration is the Milesight TS301, which is an advanced resistance temperature sensor with a visualized LCD data display. It features extendable connecting lines and a diverse range of detecting probes, including A-class, B-class, and A-class food-grade temperature probes. Moreover, it provides the option of a magnetic contact switch sensor. The sensor is designed for measuring a wide range of temperatures in harsh environments and transmitting data using LoRaWAN technology. The TS301 is widely used for temperature monitoring in applications like food processing, cold chain storage of food or medicine, etc. The device measures 4.31 inches by 2.95 inches by 1.14 inches and weighs 175 grams. In your letter, you suggest the sensors to be classified in subheading 8517.62.00, Harmonized Tariff Schedule of the United States (HTSUS). Heading 8517, HTSUS, provides in relevant part for: “…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)…”. The items concerned are environmental sensors, used to detect or measure various environmental conditions. The data generated is the function of these sensors. It is that function which is of interest to the user. How that data gets to the end use device (i.e., wired connection or wirelessly) is a support or secondary function. Without that sensor data there is no need for the transmission function. Classification under heading 8517, HTSUS, is precluded because the devices concerned are used primarily to execute a sensing/detecting/measurement function which would be beyond the scope on heading 8517, HTSUS. Furthermore, merchandise classifiable in Chapter 90, is precluded from classification in Section XVI and heading 8517, HTSUS. See Note 1(m) to Section XVI, HTSUS. The applicable subheading for the Milesight AM102 will be 9025.80.1000, HTSUS, which provides for “Hydrometers and similar floating instruments, thermometers, pyrometers, barometers, hygrometers and psychrometers, recording or not, and any combination of these instruments; parts and accessories thereof: Other instruments: Electrical.” The general rate of duty will be 1.7 percent ad valorem. The Milesight AM308 sensor module is considered a composite good in which no single element imparts the essential character to the device. Consequently, the module would be classified in accordance with General Rule of Interpretation GRI 3(c), which indicates that the goods would be classified under the heading which occurs last in numerical order among those which equally merit consideration. Heading 9027, HTSUS, which provides for, inter alia, instruments and apparatus for physical and chemical analysis and measuring or checking quantities of heat, sound or light, is the heading that appears last among those that equally merit consideration in respect to the Milesight AM308 sensor module at issue. The module’s ability to measure light, carbon dioxide, TVOC, PM2.5, and PM10 are all covered by this heading. The provisions of GRI 3(c) are applicable at the subheading level in accordance with GRI 6. As a result, when a module contains multiple elements that are classified in the same heading, and essential character cannot be determined, it would be classified under the subheading that appears last. The applicable subheading for the Milesight AM308 will be 9027.50.4050, HTSUS, which provides for “Instruments and apparatus for physical or chemical analysis (for example, polarimeters, refractometers, spectrometers, gas or smoke analysis apparatus); instruments and apparatus for measuring or checking viscosity, porosity, expansion, surface tension or the like; instruments and apparatus for measuring or checking quantities of heat, sound or light (including exposure meters); microtomes; parts and accessories thereof: Other instruments and apparatus using optical radiations (ultraviolet, visible, infrared): Other: Electrical: Photometers.” The general rate of duty will be free. The applicable subheading for the Milesight WT101 will be 9032.10.0060, HTSUS, which provides for “Automatic regulating or controlling instruments and apparatus; parts and accessories thereof: Thermostats: For air conditioning, refrigeration or heating systems: Other.” The general rate of duty will be 1.7 percent ad valorem. The applicable subheading for the Milesight TS301 will be 9025.19.8085, HTSUS, which provides for “Hydrometers and similar floating instruments, thermometers, pyrometers, barometers, hygrometers and psychrometers, recording or not, and any combination of these i

and measuring or checking quantities of heat, sound or light, is the heading that appears last among those that equally merit consideration in respect to the Milesight AM308 sensor module at issue. The module’s ability to measure light, carbon dioxide, TVOC, PM2.5, and PM10 are all covered by this heading. The provisions of GRI 3(c) are applicable at the subheading level in accordance with GRI 6. As a result, when a module contains multiple elements that are classified in the same heading, and essential character cannot be determined, it would be classified under the subheading that appears last. 

The applicable subheading for the Milesight AM308 will be 9027.50.4050, HTSUS, which provides for “Instruments and apparatus for physical or chemical analysis (for example, polarimeters, refractometers, spectrometers, gas or smoke analysis apparatus); instruments and apparatus for measuring or checking viscosity, porosity, expansion, surface tension or the like; instruments and apparatus for measuring or checking quantities of heat, sound or light (including exposure meters); microtomes; parts and accessories thereof: Other instruments and apparatus using optical radiations (ultraviolet, visible, infrared): Other: Electrical: Photometers.” The general rate of duty will be free. The applicable subheading for the Milesight WT101 will be 9032.10.0060, HTSUS, which provides for “Automatic regulating or controlling instruments and apparatus; parts and accessories thereof: Thermostats: For air conditioning, refrigeration or heating systems: Other.” The general rate of duty will be 1.7 percent ad valorem. The applicable subheading for the Milesight TS301 will be 9025.19.8085, HTSUS, which provides for “Hydrometers and similar floating instruments, thermometers, pyrometers, barometers, hygrometers and psychrometers, recording or not, and any combination of these instruments; parts and accessories thereof: Thermometers and pyrometers, not combined with other instruments: Other: Ot