H257143

H257143 August 6, 2025 OT:RR:CTF:EMAIN H257143 MFT CATEGORY: Classification TARIFF NO.: 8537.10.91 Mr. Chris Mortorff General Counsel, ADI Global Distribution 275 Broadhollow Rd., Suite 400 Melville, NY 11747 RE: Revocation of New York Ruling Letter (NY) N250956 and NY N250985; Classification of Dimmers Dear Mr. Mortorff: This letter is in response to a request received July 29, 2014, in which you seek reconsideration of New York Ruling Letter (NY) N250956 (dated March 12, 2014) and NY N250985 (dated March 17, 2014), wherein U.S. Customs and Border Protection (CBP) classified two models of certain dimmers under heading 8526 of the Harmonized Tariff Schedule of the United States (HTSUS). Following the issuance of NY N250956 and NY N250985, you informed CBP that certain information you submitted that was material to our disposition of those ruling letters was inaccurate, and you provided clarifying facts. Upon further examination of both matters, we revoke NY N250956 and NY N250985 as discussed below. Pursuant to section 625(c)(1), Tariff Act of 1930 (19 U.S.C. § 1625(c)(1)), as amended by section 623 of Title VI (Customs Modernization) of the North American Free Trade Agreement Implementation Act, Pub. L. No. 103-182, 107 Stat. 2057, 2186 (1993), notice of the proposed action was published on June 25, 2025, in Volume 59, Number 26, of the Customs Bulletin. No comments were received in response to this notice. FACTS: NY N250956 described the first dimmer model as follows: The merchandise under consideration is referred to as the ‘Wireless Adaptive Phase Dimmer,’ model C4-APD120, which is part of the ZigBee home system. This device wirelessly controls other devices through radio frequency. The buttons on this device can activate the operations of other devices controlled by the automation system, such as adjusting light levels in other rooms, turning on music, and locking the doors. In addition, this device has a subsidiary function of controlling the attached lighting load via phase-cut dimming over the line-voltage wires. Thus, it is the opinion of this office that the radio remote control function is the principal function of this device. NY N250985 described the second dimmer model in similar terms: The merchandise under consideration is referred to as the ‘Control4 120V Wireless Dimmer,’ model C4-DIM1-Z, which is part of the ZigBee home system. This device wirelessly controls other devices through radio frequency. This device can activate the operations of other devices controlled by the automation system, such as adjusting light levels, turning on music, and locking the doors. In addition, this device has a subsidiary function of controlling the attached lighting load via phase- cut dimming over the line-voltage wires. Thus, it is the opinion of this office that the radio remote control function is the principal function of this device. Both rulings classified their respective dimmer models under heading 8526, HTSUS, specifically, subheading 8526.92.50, HTSUS, which provides for, “Radar apparatus, radio navigational aid apparatus and radio remote control apparatus: Other: Radio remote control apparatus: Other.” In reaching the determinations in NY N250956 and NY N250985, CBP specifically relied on the explanations you provided in response to agency inquiries where you indicated that both models featured additional, discrete radio remote control functions for wirelessly controlling other devices. However, following the issuance of NY N250956 and NY N250985, you informed CBP that the subject dimmers do not control other devices through radio frequency (RF). Further examination of the product samples, diagrams, and your materials provided at the time of the original ruling request confirms that the dimmers do not directly use RF to control other devices. Rather, the subject dimmers each receive RF signals from a separately presented controller and, based on those signals, electrically control a lighting circuit via wires connected to the dimmer switch outputs. The submitted facts also demonstrate that the dimmers incorporate a printed circuit board assembly (PCBA) and several relays to open, close, and protect the electrical circuit. Moreover, both of the specific dimmer models at issue operate at loads not exceeding 1,000 VAC. ISSUE: Whether the subject dimmers are classified under heading 8526, HTSUS, which provides for “radio remote control apparatus,” or heading 8537, HTSUS, as “[b]oards [. . .] equipped with two or more apparatus of heading [. . .] 8536, for electric control or the distribution of electricity.” LAW AND ANALYSIS: Classification under the HTSUS is in accordance with the General Rules of Interpretation (GRIs). GRI 1 provides that the classification of goods will be determined according to the terms 2 of the headings of the tariff schedule and any relative section or chapter notes. In the event that the goods cannot be classified solely on the basis of GRI 1, and if the headings and legal notes do not otherwise require, the remaining GRIs 2 through 6 will then be applied in order. The HTSUS provisions under consideration are as follows: 8526 Radar apparatus, radio navigational aid apparatus and radio remote control apparatus: * * * * * 8537 Boards, panels, consoles, desks, cabinets and other bases, equipped with two or more apparatus of heading 8535 or 8536, for electric control or the distribution of electricity, including those incorporating instruments or apparatus of chapter 90, and numerical control apparatus, other than switching apparatus of heading 8517: Given your clarification and our review of the product samples, diagrams, and your submission, we find that the subject merchandise is not a “radio remote control apparatus” of heading 8526, HTSUS. While the dimmers may receive radio signals, the control of the lighting circuit is achieved through electrical connections, not RF. As such, heading 8526, HTSUS, is inapplicable. We instead find that the subject merchandise meets the terms of heading 8537, HTSUS. The dimmers each incorporate a PCBA (i.e., a “board”). These boards are equipped with multiple switches to open, close, and protect electrical circuits, and such switches would meet the terms of heading 8536, HTSUS. Finally, the boards are designed for electrically controlling the lighting circuit, a purpose clearly identified by the legal text. For these reasons, the subject dimmers are appropriately classified under heading 8537, HTSUS. HOLDING: By application of GRIs 1 and 6, the subject dimmers are classified under heading 8537, HTSUS, specifically subheading 8537.10.91, HTSUS, which provides for, “Boards, panels, consoles, desks, cabinets and other bases, equipped with two or more apparatus of heading 8535 or 8536, for electric control or the distribution of electricity, including those incorporating instruments or apparatus of chapter 90, and numerical control apparatus, other than switching apparatus of heading 8517: For a voltage not exceeding 1,000 V: Other.” The general column one rate of duty is 2.7 percent ad valorem. 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/. EFFECT ON OTHER RULINGS: NY N250956 (dated March 12, 2014) is hereby REVOKED. NY N250985 (dated March 17, 2014) is hereby REVOKED. 3 In accordance with 19 U.S.C. § 1625(c), this ruling will become effective 60 days after its publication in the Customs Bulletin. Sincerely, Yuliya A. Gulis, Director Commercial and Trade Facilitation Division 4

Classification under the HTSUS is in accordance with the General Rules of Interpretation (GRIs). GRI 1 provides that the classification of goods will be determined according to the terms 2 

 of the headings of the tariff schedule and any relative section or chapter notes. In the event that the goods cannot be classified solely on the basis of GRI 1, and if the headings and legal notes do not otherwise require, the remaining GRIs 2 through 6 will then be applied in order. The HTSUS provisions under consideration are as follows: 8526 Radar apparatus, radio navigational aid apparatus and radio remote control apparatus: * * * * * 8537 Boards, panels, consoles, desks, cabinets and other bases, equipped with two or more apparatus of heading 8535 or 8536, for electric control or the distribution of electricity, including those incorporating instruments or apparatus of chapter 90, and numerical control apparatus, other than switching apparatus of heading 8517: Given your clarification and our review of the product samples, diagrams, and your submission, we find that the subject merchandise is not a “radio remote control apparatus” of heading 8526, HTSUS. While the dimmers may receive radio signals, the control of the lighting circuit is achieved through electrical connections, not RF. As such, heading 8526, HTSUS, is inapplicable. We instead find that the subject merchandise meets the terms of heading 8537, HTSUS. The dimmers each incorporate a PCBA (i.e., a “board”). These boards are equipped with multiple switches to open, close, and protect electrical circuits, and such switches would meet the terms of heading 8536, HTSUS. Finally, the boards are designed for electrically controlling the lighting circuit, a purpose clearly identified by the legal text. For these reasons, the subject dimmers are appropriately classified under heading 8537, HTSUS. HOLDING: By application of GRIs 1 and 6, the subject dimmers are classified under heading 8537, HTSUS, specifically subheading