N348856

N348856 May 30, 2025 CLA-2-90:OT:RR:NC:N1:105 CATEGORY: Classification TARIFF NO.: 9025.19.8085; 9031.80.8085; 9903.01.24; 9903.01.25; 9903.88.01; 9903.88.02 Maria Lohnes DoubleDay Acquisitions, LLC dba CSafe 675 Gateway Blvd. Monroe, OH 45050 RE: The tariff classification of data loggers from China Dear Ms. Lohnes: In your letter dated May 9, 2025, you requested a tariff classification ruling. Descriptive literature was provided for our review. The first item under consideration is described as the TracSafePRO (Part #260170), which is a single-use data logger designed to capture temperature and light. The device is read by plugging in the USB connector on the side of the unit to a computer. The device also has an LCD screen to display the results, a power button, an LED indicator, and a light sensor. To start the device, the user will hold the power button for five seconds, which will start recording the data. Once the user is done using the device, they would connect it to the USB port on a computer. The results include the current temperature, number of recorded points, maximum temperature, minimum temperature, system date, and system time. Additionally, if the item is opened, the light sensor will provide an asterisk to notify that light was detected. The data logger is ideal for monitoring and recording temperature during storage and transportation for pharmaceuticals and other products. It can be used widely in all areas of warehousing, logistics, and cold chains. The device measures 97mm by 53mm by 8mm, weighs 32 grams, and is powered by a button cell battery. The second item under consideration is described as the TracSafeMAX (Part #260171), which is a reusable, Bluetooth-enabled data logger that connects directly to a smart device. Additionally, the user can plug the device into the USB port of a computer to download the recorded data. The device allows users to verify payload and ambient temperature (-30°C to +70°C), humidity (0% RH to 100% RH), light (dependent on pack out configuration), and shock events (0g to 16g). The device has a USB cap, light sensor, LCD screen, start button, stop button, and internal sensor. To start the device, the user will press the start button for three seconds. The unit will then start recording the data. Once the user is done using the device, they would hit the stop button and connect it to the USB port on a computer or obtain the information on their smart device using the app. Once the information has been downloaded, the user can reset the device to be used again. The device measures 96.3mm by 47.5mm by 19mm, weighs 68 grams, and is powered by a lithium replaceable battery. The third item under consideration is described as the TracSafeMAX – Probe (Part #260172), which is a reusable, Bluetooth-enabled data logger that connects directly to a smart device. Additionally, the user can plug the device into the USB port of a computer to download the recorded data. This device is nearly identical to the second item but also includes an additional temperature sensor probe. The device allows users to verify ambient temperature using the internal device (-30°C to +70°C), external temperature using the probe routed into the package or crate (-200°C to +150°C), humidity (0% RH to 100% RH), light (dependent on pack out configuration), and shock events (0g to 16g). The device has a USB cap, light sensor, LCD screen, start button, stop button, internal sensor, and external probe. To start the device, the user will press the start button for three seconds. The unit will then start recording the data. Once the user is done using the device, they would hit the stop button and connect it to the USB port on a computer or obtain the information on their smart device using the app. Once the information has been downloaded, the user can reset the device to be used again. The device measures 103.3mm by 47.5mm by 19mm, weighs 68 grams, and is powered by a lithium replaceable battery. The fourth item under consideration is described as the TracSafe NFC Label (Part #160-0002), which is a compact, near field communication (NFC)-enabled smart tag with built-in environmental sensor. When a user scans the label with an NFC-capable mobile device, data is transferred wirelessly to the TracSafe app. The user would click the start button on their app and input all of the parameters needed. Once the user hits the start button again on their app, the tag will be turned on. The user also has the ability to start numerous tags at once using the same parameters. Once the cargo has been shipped, the user can scan the tag and view the temperature data, battery level, alarms and other information. They can also click the route icon on the app to obtain the location information. Once the user has obtained all of the information, they would hit the end button and then tap the device to stop working. The device measures 135mm by 100mm by 1mm, weighs 5 grams, and uses a non-Li paper battery. In your letter, you suggest the classification of the TracSafePRO (Part #260170), TracSafeMAX (Part #260171), the TracSafeMAX – Probe (Part #260172), and the TracSafe NFC Label (Part #160-0002) to be under heading 8517, Harmonized Tariff Schedule of the United States (HTSUS), which 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)…”. We disagree. We find the core function of each sensor to be the measuring/checking. It is the calculated measurement 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 the measurement data, there is no need for the transmission function. Additionally, on the first three units, the measurements are provided to the user on the integrated display. Therefore, classification under heading 8517, HTSUS, is precluded because each of the environmental sensors are used primarily to execute a measurement function which would be beyond the scope on heading 8517, HTSUS. Classification under the HTSUS is made in accordance with the General Rules of Interpretation (GRIs). GRI 1 provides that the classification of goods shall be determined according to the terms of the headings and any relevant section or chapter notes. In the event the articles cannot be classified solely on the basis of GRI 1, GRIs 2 through 6 may be applied in order, as appropriate. The Explanatory Notes to the HTSUS, while not legally binding, may also be consulted to aid in classification. The sensors listed above are considered to be composite goods within the meaning of GRI 3. Goods classifiable under GRI 3(b) shall be classified as if they consisted of the material or a component which gives them their essential character. The Explanatory Note to GRI 3(b)(VIII), states that the factors which determine essential character will vary between different kinds of goods. It may, for example, be determined by the nature of the materials or components, its bulk, quantity, weight or value, or by the role of a constituent material in relation to the use of the goods. GRI 3(c) states that when the essential character of a composite good cannot be determined, classification is based on the heading that occurs last in numerical order among those which equally merit consideration. It is the opinion of this office that the TracSafePRO’s temperature reading ability in heading 9025, HTSUS, is the essential character of the device, GRI 3(b) noted. We consider the light sensing ability in heading 9027, HTSUS, to be a secondary feature as it is simply used to determine if the container has been opened, however, the temperature reading is always utilized. Additionally, in our opinion, the TracSafeMAX and TracSafeMAX – Probe’s temperature and humidity abilities in heading 9025, HTSUS, merit equal consideration to the sho

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) Steven A. Mack Director National Commodity Specialist Division