Background

In the Sept. 29, 2021, Customs Bulletin and Decisions, U.S. Customs and Border Protection is proposing to reclassify fleet telematics devices as radio navigational aid apparatus under HTSUS 8526.91.00 (duty-free) or other instruments, appliances, and machines under HTSUS 9031.80.80 (duty-free) rather than as machines for the transmission of data under HTSUS 8517.62.00 (duty-free) or radio navigational aid apparatus under HTSUS 8526.91.00.

The products at issue monitor a variety of vehicle and cargo information (i.e., location, driver behavior, vehicle activity, engine diagnostics, environmental conditions) and transmit that data in real time to fleet operators to enable them to manage their resources. Simpler devices may feature only a cellular modem and GPS; other devices may include additional integrated components that function to obtain data that is specific to the needs of the end-user.

The articles at issue feature key components such as a cellular modem, GPS, code reader, and accelerometer. Each of these components contributes equally to the device’s function, leading CBP to conclude that no single key component imparts the principal function. CBP has therefore classified the devices in the heading that occurs last in numerical order among the competing headings that equally merit consideration.

Rulings NY N304264, NY N213872, NY N108329, NY N300201, NY N301862, NY N201495, NY N108330, and NY N148555 would be revoked, and ruling NY N168766 would be modified, to reflect this change in classification. Comments on this proposal are due no later than Oct. 29.

For more information on how to seek or utilize classification and other rulings, please contact attorney Deb Stern at (305) 894-1007 or via email.

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