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Newly Released CBP HQ Rulings Oct. 16

The Customs Rulings Online Search System (CROSS) was updated Oct. 16 with the following headquarters rulings (ruling revocations and modifications will be detailed elsewhere in a separate article as they are announced in the Customs Bulletin):

H325234: Request to reconsider HQ H323185; Tariff classification of an automotive telematics device with cellular modem, GPS, code reader, accelerometer/gyroscope

Ruling: The DataLogger DCM970 GEN 3 is classified under Harmonized Tariff Schedule subheading 9031.80.80 as “measuring or checking instruments, appliances and machines, not specified or included elsewhere in this chapter; profile projectors; parts and accessories thereof: other instruments, appliances and machines: other.”
Issue: What is the correct tariff classification of the DataLogger DCM970 GEN 3?
Item: An automotive telematics device. The DCM970 is designed to be installed in a vehicle’s engine diagnostics port. It is used to collect, analyze, and transmit data about the vehicle to a server via the global cellular network. The key components include an accelerometer/gyroscope, GPS, OBD-II code reader , and cellular modem/transceiver. The accelerometer/gyroscope detects gravitational force to collect data on braking, acceleration, and cornering. The GPS collects vehicle location data. The reader function is used to pull data from the car’s computer and sensors. The cellular modem/transceiver processes, converts, and transmits to servers the data collected by other components.
Reason: The subject merchandise is a composite machine and is properly classified according to its principal function. While the subject merchandise does feature a cellular modem or transceiver that, on its own, would likely be classified under HTS heading 8517, the scope of that provision does not cover a device that also features a GPS component and an accelerometer/gyroscope. The DCM970 is not itself a data transmission device.
Ruling Date: Oct. 12, 2023