N350642

N350642 July 16, 2025 CLA-2-90:OT:RR:NC:N1:105 CATEGORY: Classification TARIFF NO.: 9025.19.8085; 9025.80.1000; 9027.50.4050; 9031.80.8085; 9903.01.24; 9903.01.25; 9903.88.01; 9903.88.02 Farhad Arvin Choovio Inc. 23191 La Cadena Drive, Suite 102 Laguna Hills, CA 92653 RE: The tariff classification of sensors from China Dear Mr. Arvin: In your letter dated June 25, 2025, you requested a tariff classification ruling. Descriptive literature was provided for our review. The first item under consideration is the Senstick SSM40, which is a LoRaWAN-based soil moisture sensor designed to monitor volumetric water content in soil. It operates autonomously for up to 7 years in harsh conditions, making it particularly useful in remote or unattended environments. The SSM40 generates variable electrical signals corresponding to the Volumetric Water Content (VWC) of the soil, ranging from 0% to 100%. These signals are interpreted internally and converted into digital data, which is then transmitted over LoRaWAN. The output is a calibrated measurement, not just a simple trigger. It delivers real-time, quantitative readings to the user or system, which can then be viewed via dashboard or LoRaWAN network server integration. The sensor uses capacitive measurement technology (typical for VWC sensing) in the EC-5 soil probe, which detects dielectric changes in the soil to determine water content. The sensing element is part of an EC-5 probe, which is recognized industry-wide for high-accuracy readings in soil environments. Additionally, the unit includes motion detection (accelerometer) with a sensing range of ±2g to ±16g, which may help detect if the sensor has been moved or disturbed (useful for anti-tamper or deployment verification). The second item under consideration is the KARE+ 3-in-1 sensor, which is designed to monitor indoor environmental conditions. It integrates three key sensing functions including smoke detection, temperature measurement, and humidity measurement. The sensor is designed to alert occupants to smoke, track room temperature for comfort, and monitor humidity for mold prevention. The sensor is used to maintain suitable living conditions, to monitor room climate and detect environmental anomalies early as a supplement to non-connected smoke detectors, and offers smart monitoring with LoRaWAN connectivity. Each sensor in the device provides variable electrical output that represents measurements, which are processed and transmitted via LoRaWAN 915 MHz to a gateway or compatible platform. The temperature and humidity sensors provide precise, calibrated measurement values. The smoke detector uses a photoelectric (optical) sensing method to generate signals indicating smoke presence. These outputs are formatted as data packets that represent real measurements, not just binary alert signals. The device provides actual calibrated measurements including temperature in degrees Celsius (°C) with a range of -30°C to +70°C and humidity in percentage relative humidity (0-100% RH). The smoke sensor, while using optical technology, also triggers an alert with details transmitted through the network and produces a local audible alarm (85 dB at 3 meters). The smoke detector has photoelectric detection using the Tyndall effect (scattering of light by smoke particles). The smoke alarm alerts to fire or burning material, which enhances occupant safety. The temperature sensor allows for environmental control, detection of HVAC malfunctions, or risk of overheating/freezing, while the humidity sensor helps prevent mold growth, identify leaks, and maintain comfort levels. The third item under consideration is the LHT65N-VIB, which is a LoRaWAN-enabled vibration sensor used to detect and measure vibrations, shocks, or accelerations of an object in real time. It is typically deployed for machine monitoring while detecting abnormal vibration patterns to predict mechanical failure, pump monitoring by notifying maintenance teams when unexpected motion occurs, and water leak detection when used in combination with environmental clues or sudden vibrations (e.g., pipe bursts). The device is built for remote, professional applications where long-range data transmission and low-power consumption is critical. The LHT65N-VIB outputs calibrated sensor readings representing vibration intensity and status using a 3-axis accelerometer (x, y, z). It also provides environmental readings such as temperature (°C) and humidity (%RH). Users receive these readings over LoRaWAN, which can be visualized via dashboards or trigger cloud-based alerts/actions. The temperature sensing is designed to monitor equipment operating environments, provide early warning for overheating or environmental stress, and supplement vibration data for more complete diagnostics. The humidity sensor is similar and can flag issues like condensation in sensitive machinery. The fourth item under consideration is the RB11E, which is a multi-functional LoRaWAN sensor designed for indoor environmental monitoring. It combines occupancy detection, temperature sensing, and light level monitoring in a single compact device. The sensor can be used to detect human presence to automate lighting and HVAC systems, trigger systems based on room usage to reduce power waste, and alert if motion is detected during scheduled non-occupancy hours. The sensor can also provide lighting control where it can adjust lighting based on ambient light readings. The RB11E generates calibrated digital measurements transmitted via LoRaWAN. Each sensor’s data is represented as a structured variable (not raw voltage), understandable by compatible gateways or platforms. The temperature is provided in degrees Celsius (20°C to 55°C), light levels in Lux (range 2–1100 Lux), occupancy sensor using a Fresnel lens for a wide sensing field (horizontal: 110°, vertical: 60°), occupancy detection via a binary motion alert (event trigger), tamper alert via an event-based trigger, and battery level in Volts (±0.1V accuracy). Each sensor triggers signal transmission when thresholds are crossed or periodic reports are scheduled. There are no built-in audible or visual alarms, however, alerts can be sent to external systems which can be configured to activate alarms, lights, or notifications. The fifth item under consideration is the Strips Multi-sensor +Guard, an ultra-slim magnetic contact sensor designed for monitoring windows, doors, gates, and valuable items. The sensor can provide building security by detecting unauthorized entry by alerting when doors/windows are opened. It can also automatically disable the HVAC systems when windows are opened, monitor environmental conditions and intrusion in commercial and residential buildings, discreetly monitor access to drawers, cabinets, or even behind picture frames for security in museums, offices, and homes. The sensor’s ultra-thin (3mm) and long-range (up to 10 km) design allows for hidden indoor or outdoor installations, making it highly flexible for both professional and consumer IoT applications. The sensor generates LoRaWAN radio packets that encode Open/Close (binary signal from the magnetic contact sensor) and temperature data (variable calibrated measurement in °C/°F). In your letter, you suggest the applicable classification for the sensors to be within heading 8517, 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 have a primary function of measuring/ detecting/ sensing various environmental conditions. They also have a secondary function of transmitting that information to a remote location. As per the Explanatory Notes to heading 8517, carrier-current and other transmitters and receivers which form a single unit with analogue or dig

and measuring or checking quantities of heat, sound or light, is the heading that appears last among those that equally merit consideration. The applicable subheading for the RB11E 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. For item 5, heading 9025, which provides for instruments for measuring temperature, is the heading that appears last among those that equally merit consideration. The applicable subheading for the Strips 

Multi-sensor +Guard sensor 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: Other: Other: Other.” The general rate of duty will be free. Effective March 4, 2025, pursuant to U.S. Note 2(u) to Subchapter III, Chapter 99, all products of China and Hong Kong as provided by heading 9903.01.24, HTSUS, other than products classifiable under headings 9903.01.21, 9903.01.22, and 9903.01.23, HTSUS, will be subject to an additional 20 percent ad valorem rate of duty. At the time of entry, you must report the applicable Chapter 99 heading, i.e., 9903.01.24, in addition to subheadings 9025.19.8085, 9025.80.1000, 9027.50.4050, and 9031.80.8085 HTSUS, listed above. Effective April 5, 2025, Executive Or