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HQ 955497

February 10, 1994

CLA-2 CO:R:C:M 955497 MBR


TARIFF NO.: 8531.20.00

Mr. Perry Sobol
Traffic Admin.
American Telecommunications Corporation
P.O. Box 7266
Charlottesville, VA 22901

RE: Caller ID Unit; Signalling Apparatus; Telephonic Apparatus; 8531; 8517; HQs 954390, 953366

Dear Mr. Sobol:

This is in reply to your letters of September 13, 1993, and November 18, 1993, requesting the classification of a "Caller ID," under the Harmonized Tariff Schedule of the United States (HTSUS). Your letters were forwarded to this office for reply.


The American Telecommunications Corporation telephone "Caller ID" unit, model number ATADJ-CG-100, is a device that displays the telephone number of a calling party on a liquid crystal display (LCD). The unit plugs into a standard telephone modular wall jack. A coded representation of the calling party's telephone number is sent on the telephone line to the unit, where the caller's telephone number is displayed. The caller's number is also stored in chip memory so that the user can review the information at a later date. The Caller ID also records the time and date of call. The unit operates independently of the telephone and does not require the attachment of a telephone in order to operate properly.


Is the Caller ID unit classifiable under heading 8531, HTSUS, as electric sound or visual signalling apparatus, or under heading 8517, HTSUS, as electrical apparatus for line telephony?


The General Rules of Interpretation (GRI's) to the HTSUS govern the classification of goods in the tariff schedule. GRI 1 states, in pertinent part:

...classification shall be determined according to the terms of the headings and any relative section or chapter notes...

The current legal precedent for the classification of Caller ID units is HQ 953366, dated April 5, 1993, as affirmed by 954390, dated October 7, 1993, which held that Caller ID units were classifiable in heading 8531, HTSUS, which provides for signalling apparatus. In HQ 953366 Customs cited the Harmonized Commodity Description and Coding System Explanatory Notes ("ENs") regarding heading 85.31, page 1382, which state that signalling apparatus includes:

Number indicators. The signals appear as illuminated figures on the face of a small box; in some apparatus of this kind the calling mechanism is operated by the dial of a telephone.

Although not dispositive, the ENs are to be used for guidance in determining the proper interpretation of the HTSUS. 54 Fed. Reg. 35128 (August 23, 1989).

Additionally, in HQ 953366 Customs stated the following: "[a]lthough the devices appear to be prima facie described by heading 8517, HTSUS, they are still classified in heading 8531, HTSUS, where they are more specifically provided for pursuant to GRI 3." Thus, we relied on GRI 3(a), which provides that: "[t]he heading which provides the most specific description shall be preferred to headings providing a more general description."

Therefore, signalling apparatus, such as Caller IDs, whose sole purpose and function is merely signalling, and particularly apparatus which is enumerated in the ENs in heading 85.31, is properly classifiable in heading 8531, HTSUS.


The American Telecommunications Corporation telephone Caller ID unit, model ATADJ-CG, is classifiable in subheading 8531.20.00,

HTSUS, which provides for signalling apparatus. The rate of duty is 2.7 percent ad valorem.


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