N351344

N351344 July 30, 2025 CLA-2-85:OT:RR:NC:N2:209 CATEGORY: Classification TARIFF NO.: 8517.62.0090, 9903.01.32, 9903.01.24, 9903.88.15 Anthony Zhu Hanshow America Inc. No. 1288 Kanghe Rd., Xiuzhou District, Jiaxing City, Zhejiang Province, China RE: The tariff classification of Electronic Shelf Label (ESL) Controllers from China or Taiwan Dear Mr.. Zhu: In your letter dated July 15, 2025, you requested a tariff classification ruling. The items concerned are referred to as Electronic Shelf Label (ESL) Controllers (Model Numbers HS C09960 and HS C09979). These devices are wireless access points (AP). They are responsible for the data transmission and information interaction between an electronic shelf label (i.e. pricing label used to display the price of an item in a store) and a remote computer system that runs the electronic pricing system architecture. The electronic shelf label controller is responsible for the two-way data transmission between the price tag work system (remote computer system) and the electronic shelf labels (shelf mounted electronic pricing label displays). The product operates on the 2.4GHz wireless frequency band. This product connects to the price tag work system via an Ethernet interface (POE) and establishes bidirectional 2.4GHz wireless communication with electronic shelf labels to transmit data and images. The downlink is where this product receives downlink packets from the price tag work system to perform updates, networking, upgrades, flash updates, and global operations on electronic shelf labels. The uplink is where the product forwards heartbeat packets and other information from the electronic shelf label to the price tag work system platform based on the electronic shelf label wireless protocol standard. The applicable subheading for the Electronic Shelf Label (ESL) Controllers (Model Numbers HS C09960 and HS C09979) will be 8517.62.0090, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Telephone sets, including smartphones and other telephones for cellular networks or for other wireless networks; 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)…: Other apparatus for 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): Machines for the reception, conversion and transmission or regeneration of voice, images or other data, including switching and routing apparatus: Other.” The general rate of duty will be Free. Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time products from all countries will be subject to an additional 10 percent ad valorem rate of duty. Your product falls within an excepted subheading. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.01.32, in addition to subheading 8517.62.0090, HTSUS, listed above. 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 subheading 8517.62.0090, HTSUS, listed above. Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheadings 8517.62.0090, HTSUS, unless specifically excluded, are subject to an additional 7.5 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.15, in addition to subheading 8517.62.0090, HTSUS, listed above. The tariffs and additional 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/. 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 Steven Pollichino at steven.pollichino@cbp.dhs.gov. Sincerely, (for) James Forkan Acting Director National Commodity Specialist Division

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 Steven Pollichino at steven.pollichino@cbp.dhs.gov. 
Sincerely,
 (for) James Forkan Acting Director National Commodity Specialist Division