CBP Says Bluetooth Capability Doesn't Determine Classification of iPhone Case With Separate Screen

An iPhone case that includes a separate screen that shows information from the phone sent through a Bluetooth connection isn't classified based on the Bluetooth capability, CBP said in an Aug. 3 ruling. The ruling, HQ H275685, came in response to an internal advice request from a customs broker for the maker of the phone case, popSLATE Media. The request went through CBP's Electronics Center of Excellence and Expertise, it said.

The case includes a built-in screen that can display photographs, boarding passes, maps and other things from the user's phone. The case uses a separate battery and receives the display content from the iPhone through a Bluetooth connection, CBP said. The company told CBP it believes the cases are best classified in heading 8517 based on the radio transceivers. The agency previously classified the Apple Watch and other "smartwatches" in heading 8517 based on the radio transceivers in the watches that impart the essential character of the devices (see 1603070028).

CBP disagreed over what gives the product the essential character. "The various functions of the popSLATE case suggest that functionality should determine the essential character of the case," CBP said. "The most prominent feature of these three functions is the image display screen, as it is the function which distinguishes the popSLATE case from most other protective cases for mobile phones. It is also the feature that is marketed most aggressively as the purpose of the popSLATE case."

Here, the display screen doesn't transmit data to other devices "and none of the popSLATE’s functions provide any functionality beyond supporting its image displaying function," CBP said. "This is [in] contrast to another device that contains a wireless transmitter that we recently ruled upon." The case is more like a TV, which isn't classified based on its "reception apparatus," CBP said. Instead, "the Bluetooth functionality merely serves as a connection between a smart phone and the display." It's the video display function that gives the essential character, CBP said. The case is best classified in subheading 8543.70.99 as “Electrical machines and apparatus, having individual functions, not specified or included elsewhere in this chapter; parts thereof: Other machines and apparatus: Other: Other: Other... .” That classification has a 2.6 percent duty rate.