Wireless Charging Cases for iPads Not Classifiable as Containers, CBP Says

Cases for iPads that allow for wireless charging through a separate charging base are not classifiable as “similar containers” under heading 4202, CBP said in a June 28 ruling. The ruling, HQ H287462, was in response to a request for further review of a protest filed by Dana Innovation, the parent company of Sonance. CBP liquidated such iPad cases in 4202.99.9000 with a 20 percent duty rate.

The iPad cases at issue have "internal electrical components that enable the sleeves to work as charging devices," CBP said. When used with the charging base, "high frequency alternating current flowing within the transmitter induction coil in the charging base creates a magnetic field that wirelessly extends to the receiver induction coils in the sleeves," the agency said. "The receivers’ electronic circuitry converts that alternating current into direct current that is then used to charge the internal batteries of iPads inserted into the sleeves." CBP based much of its analysis as in a 2016 U.S. Court of Appeals for the Federal Circuit decision on the classification of cellphone cases (see 1608260024).

The sleeves at issue aren't classifiable in heading 4202 because "because they are not of the materials specifically named in the second half of the heading," CBP said. Also, the iPad cases differ from the other articles mentioned in the subheading. "Here, the function of each charging sleeve as a whole is to charge iPads and the electrical components within the sleeves are indispensable to that function. While the plastic components of the sleeves hold iPads as they are charged, they offer only minimal protection and serve no other functions," the agency said. "We therefore find that the electrical components provide the essential character of the charging sleeves."

Instead, the cases are best classified in heading 8504, CBP said. "The instant sleeves are clearly used to convert electrical energy in order to adapt it for further use," the agency said. "Therefore, the sleeves are properly classifiable in subheading 8504.40.70, [of the Harmonized Tariff Schedule of the U.S. (HTSUS)], which provides, in relevant part, for other power supplies for automatic data processing machines or units thereof of heading 8471." That classification is duty-free.