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NY R01279

February 9, 2005

CLA-2-90:RR:NC:N1:105 R01279


TARIFF NO.: 9025.80.1000

Ms. Jean Thompson
RJT Customs Broker
247 Utah Avenue South
San Francisco, CA 94080

RE: The tariff classification of a Wayfinder V2020 from China

Dear Ms. Thompson:

In your letter dated January 7, 2005, for the PNI Corpoation, you requested a tariff classification ruling. No sample was submitted.

The information you attached describes the Wayfinder V2020:

“Wireless Installation
Based on radio frequency and battery operation, so mounting is quick and easy with no dangling wires cluttering your dash

Full Spectrum Temperature Range
Measures from - 35F to 120F, in Fahrenheit or Celsius

Maximum Versatility
Additional Temp Sensor for measuring inside vehicle temperature available by special order; or use simple instructions to change your Outside Temp Sensor to an Inside Temp Sensor

All-Weather Performance
Designed to withstand extreme temperatures; no need to remove sensor during peak winter/summer weather

Ice Alert
Warns of hazardous road conditions when temperature drops to +35F

Magnetic Distortion Flag
Alerts you when magnetic interference is affecting compass accuracy”

While the compass is relatively sophisticated, only the temperature function requires the RF transmitter and receiver and it has additional features compared to simple thermometers, such as the Ice Alert. We note that resellers on the WWW usually refer to both the directional and temperature aspect of the V2020 in their heading description.

In the HTS, thermometers are classified after Compasses (9015). See Harmonized System General Rule of Interpretation 3-c.

While no details are given on the measurement method used by the thermometer, it appears to be “electrical” per Add. US Note 2 to Chapter 90.

The applicable subheading for the V2020 will be 9025.80.1000, Harmonized Tariff Schedule of the United States (HTS), which provides for, inter alia, “electrical” thermometers, combined with other instruments. The rate of duty will be 1.7 percent ad valorem.

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 J. Sheridan at 646-733-3012.


Robert B. Swierupski

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