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NY L86295

August 1, 2005

CLA-2-85:RR:NC:N1:112 L86295


TARIFF NO.: 8543.89.9695

David Williams
Warehouse Manager,
330 Hastings Drive
Buffalo Grove, IL 60089-6940

RE: The tariff classification of a remote-controlled pet training system from China

Dear Mr. Williams:

In your letter dated July 5, 2005, you requested a tariff classification ruling.


The item concerned is the Innotek Two Dog Basic Trainer (# BT-502A). It includes –

Two 23”, water-resistant, nylon pet collars with plastic buckles – each with an attached hard plastic-enclosed electrical generator with two ½” silver prongs extending from it to the inner portion of the collar. On the outer portion of each generator box is a small LED;

A 3 ½” in length X 2 ¼” in width hand-held transmitter;

A 20”, textile, neck lanyard;

Two six-volt batteries;

4 metal, replacement collar prongs;

An arrowhead-shaped piece of hard plastic with a light bulb at its apex;

An oblong piece of metal with two hexagon-shaped cutouts in it.

The purpose of the item is to apply electric shocks of varying degrees to a pet in order to train it.

Tariff Classification:

Classification in the Harmonized Tariff Schedule of the United States (HTS) is governed by the General Rules of Interpretation (GRIs).

GRI 1. states, “... classification shall be determined according to the terms of the headings and any relative section or chapter notes ... “.

Section XVI, Note 4. states, “When a machine (including a combination of machines) consists of individual components (whether separate or interconnected ... ) intended to contribute together to a clearly defined function covered by one of the headings in ... chapter 85, then the whole falls to be classified in the heading appropriate to that function.”

All of the components of the Innotek Two Dog Basic Trainer (# BT-502A) act together to contribute to the single function of training a pet through administering shocks of varying intensities, therefore they may be classifiable together in one heading.

HTS heading 8543 provides for “Electrical machines and apparatus, having individual functions, not specified or included elsewhere ... “.

General Note 3. (h) (vi) states, “ ... a reference to “headings” encompasses subheadings indented thereunder.”.

The applicable subheading for the Innotek Two Dog Basic Trainer (# BT-502A) will be 8543.89.9695, Harmonized Tariff Schedule of the United States (HTS), which provides for “Electrical machines and apparatus, having individual functions, not specified or included elsewhere ... : Other machines and apparatus: Other: Other: Other: Other: Other”. The rate of duty will be 2.6%.

This ruling is being issued under the provisions of Part 177 of the Customs 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, contact National Import Specialist Richard Laman at 646-733-3017.


Robert B. Swierupski

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