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NY N020422




December 14, 2007

CLA-2-85:OT:RR:NC:N1:112

CATEGORY: CLASSIFICATION

TARIFF NO.: 8531.90.9000

Douglas P. Beebe
Affiliated Customs Brokers USA, Inc.
193 West Service Road
Champlain, New York 12919

RE: The tariff classification of components of the “Securalert Emergency Call System” from Canada

Dear Mr. Beebe:

In your letter dated November 28, 2007, on behalf of Nordicom Inc., you requested a tariff classification ruling.

The items concerned are ultrasonic transmitters and ultrasonic receivers which are components of the “Securalert Emergency Call System”. The ultrasonic transmitters and ultrasonic receivers work together (specific transmitters work with specific receivers) as part of an emergency distress call system.

The first item concerned is the TS-200 Ultrasonic Transmitter. This ultrasonic transmitter is a light, portable, battery operated, “panic button”. When the button on this device is pressed, an ultrasonic alarm signal is transmitted to an ultrasonic receiver. The TS-200 works with the RS-100 or RS-200 ultrasonic receiver units. The TS-200 incorporates a metal ring and clip which allows it to be worn on any piece of clothing.

The second item concerned is the TS-300 Modulated Ultrasonic Transmitter. This device is a light, portable, battery operated, “panic button”. When the button on this device is pressed an ultrasonic alarm signal is transmitted to an ultrasonic receiver. The TS-300 works with the RS-200 or RS-900 (modulated) ultrasonic receiver units. The TS-300 incorporates a metal ring and clip which allows it to be worn on any piece of clothing.

The third item concerned is the RS-200 Supervised Ultrasonic Receiver. This device consists of an electronic circuit that fits into a “one gang” type electrical box. It comes with a brushed stainless steel cover plate. The RS-200 would need to be hard-wired to an electrical system (for power) and either an alarm or surveillance system. The RS-200 is designed to work with the TS-100 ultrasonic transmitter. When the RS-200 receives an ultrasonic signal from a transmitter a red LED on the receiver lights up and the signal is communicated to either an alarm or a surveillance system.

The forth item concerned is the RS-900 Wireless, Supervised, Modulated Ultrasonic Receiver. The RS-900 is a wireless, battery operated unit that comes mounted within a plastic housing that incorporates a brushed stainless steel cover plate. The RS-900 is designed to work with the TS-900 or TS-200 version 2 ultrasonic transmitters. When the RS-900 receives an ultrasonic signal from a transmitter, a red LED lights up on the receiver and a radio message is transmitted to a master receiver, alerting the appropriate personnel to the distress call.

In use, a receiver would be installed within close proximity (within the same room) to the party or area being monitored. When the panic button on the transmitter is pressed an ultrasonic signal is transmitted to the receiver unit. The receiver unit then forwards that distress signal to a central alarm/control system or a master receiver. Based on that signal the exact location of the individual in distress can be ascertained. Contrary to radio waves, ultrasonic signals bounce off walls, floors and ceilings (radio waves penetrate walls, floors and ceilings). Therefore, these ultrasonic transmitters will only activate the receiver located within the same room, making it possible to accurately pinpoint the location of the distress call. These ultrasonic units would be best suited for situations where an emergency might occur and one quickly needs to find the exact location of the person in distress, within a building that has many different closed rooms.

The applicable subheading for each of these components, (TS-200 Ultrasonic Transmitter, TS-300 Modulated Ultrasonic Transmitter, RS-200 Supervised Ultrasonic Receiver, RS-900 Wireless, Supervised, Modulated Ultrasonic Receiver) will be 8531.90.9000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electric sound or visual signaling apparatus: Parts: Other: Other”. The rate of duty will be 1.3%.

Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.

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 Steve Pollichino at 646-733-3008.

Sincerely,

Robert B. Swierupski
Director,

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