N347798

N347798 April 28, 2025 CLA-2-85:OT:RR:NC:N2:209 CATEGORY: Classification TARIFF NO.: 8531.20.0020, 9903.01.25 Elizabeth Lowe Venable LLP 600 Massachusetts Ave., NW Washington, DC 20001 RE: The tariff classification of an LCD home automation hub from Vietnam Dear Ms. Lowe: In your letter dated April 14, 2025, you requested a tariff classification ruling. The item concerned is referred to as “The Vivint Smart Hub Pro.” This device is an LCD control panel that wirelessly connects to various smart home devices and security systems within the Vivint ecosystem. It features a user-friendly touchscreen interface that allows users to monitor and control security sensors, cameras, door locks, thermostats, and other connected devices. The panel uses prominent icons to deliver critical status updates, alerts, and event notifications. It allows access to activity history, video and audio communication, security system arming and disarming, configuration and operation of connected devices, and emergency features. The key features of the Smart Hub Pro are as follows: 7’’ capacitive, color liquid crystal display (“LCD”) touchscreen. Built-in smoke, carbon monoxide (CO), and glass break monitoring. Built-in speakers and microphones support two-way voice communication with Vivint’s 24/7 professional monitoring centers. View live video and recorded clips if cameras are installed. 85dB siren Status LED to indicate whether the alarm system is armed or disarmed. Dual-band Wi-Fi and LTE cellular connectivity. Built-in Z-wave technology enabling HVAC, appliance, lighting, and security control. Built-in encrypted cellular communication unit. Remote management from a computer or internet-enabled phone. 24-hour backup rechargeable battery. 345mHz radio interface links sensor signals back to the panel. The panel communicates with users and Vivint’s 24/7 professional monitoring centers via cellular and internet connections and interacts with home security and safety devices (e.g., smoke detectors) through a 345 MHz radio frequency. It controls home automation devices (e.g., door locks, thermostats) by Z-waveTM (910Mhz) radio and communicates with security cameras using Wi-Fi and Ethernet. The Smart Hub Pro incorporates internal sensors that are used for detecting various home security occurrences (i.e. glass breakage, smoke, carbon monoxide (CO) and proximity sensors) When triggered, these sensors alert the user and provide options to report a real emergency, indicate a false alarm, or connect with the monitoring center if they are uncertain. The Smart Hub Pro is used to display limited information about home automation and security devices, such as signaling to users when these devices detect a specific event set by the users. It primarily uses easily recognizable icons rather than text to convey critical status updates, alerts, and event notifications. The Smart Hub Pro allows users to configure and manage various connected devices and set personalized audio alerts and notifications for specific conditions. In addition to the LCD indicator panel the Smart Hub Pro also incorporates an 85dB siren triggered by events such as a potential security breach, fire, or carbon monoxide risk. The “Vivint Smart Hub Pro,” meets the definition of a composite machine as it acts as a data transmission/reception hub, and a sound/visual signaling device. The classification of composite machines is governed by Note 3 to Section XVI, HTSUS, which states, in relevant part, that “machines designed for the purpose of performing two or more complementary or alternative functions are to be classified as if consisting only of that component or as being that machine which performs the principal function.” In addition, General Explanatory Note (VI) to Section XVI states, with respect to multi-function machines and composite machines, that where it is not possible to determine the principal function and where, as provided in Note 3 to Section XVI, the context does not otherwise require, it is necessary to apply General Rule of Interpretation (GRI) 3(c). GRI 3(c) requires classification in the last heading from among those which equally merit consideration. In this case, it is our opinion that the functions (data transmission/reception and audio/visual signaling) are of equal merit. The two headings which merit equal consideration are heading 8517, HTSUS, which provides 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)…” and heading 8531, HTSUS, which provides for “Electric sound or visual signaling apparatus (for example, bells, sirens, indicator panels, burglar or fire alarms), other than those of heading 8512 or 8530; parts thereof.” As there is no one principal function, the “Vivint Smart Hub Pro,” is classifiable in accordance with GRI 3 (c), within heading 8531, HTSUS, as that is the heading to appear last in the tariff. The applicable subheading for the “Vivint Smart Hub Pro,” will be 8531.20.0020, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electric sound or visual signaling apparatus (for example, bells, sirens, indicator panels, burglar or fire alarms), other than those of heading 8512 or 8530; parts thereof: Indicator panels incorporating liquid crystal devices (LCD's) or light emitting diodes (LED): Incorporating LCD’s.” 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. Products of China, including Hong Kong and Macau, will be assessed an additional ad valorem rate of duty of 125 percent. Products from all other countries will be subject to an additional 10 percent ad valorem rate of duty. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.01.25, in addition to subheading 8531.20.0020, HTSUS, listed above. 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, Steven A. Mack 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,
 Steven A. Mack Director National Commodity Specialist Division