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We disagree. While the item concerned does incorporate a data transmission/reception function, it is the opinion of this office that the data transmission/reception functionality is not the primary function of the device. The primary function of this device is to automatically dispense medication. Based on the information supplied, the item is beyond the intended scope of heading 8517, HTSUS.—————————————————————————————————————————————————————————-
RE: The tariff classification of an automatic medication dispenser from China.
In your letter dated September 4, 2019, you requested a tariff classification ruling.
The product under consideration is identified as the Pria Home Companion (“Pira”). It is an automated medication storage and dispensing management device. Using voice and facial recognition, the device will dispense medication. It can store up to 28 separate doses in advance, with each slot capable of holding 10 pills. Through smartphone app integration, the Pria allows a caregiver to monitor an individual’s medication and healthcare schedule. In addition to automatically dispensing medications in a timely manner, the voice and facial recognition features help prevent unauthorized access to pills contained in the Pria. A manual key pad can also be used to access medications. As an auxiliary function, the Pria will respond to a patient’s questions including about the weather, number of calories in different foods, and it will set reminders. The unit has a self-contained electric motor powered by a lithium battery. It measures approximatey 8.5 inches by 6.2 inches by 12.5 inches and weighs 4.9 lbs.
Your request states you believe the Pria Home Companion should be classified under subheading 8517.62, Harmonized Tariff Schedule of the United States (HTSUS), which provids for machines for the reception, conversion and transmission or regeneration of voice, images or other data, including switching and routing apparatus.
We disagree. While the item concerned does incorporate a data transmission/reception function, it is the opinion of this office that the data transmission/reception functionality is not the primary function of the device. The primary function of this device is to automatically dispense medication. Based on the information supplied, the item is beyond the intended scope of heading 8517, HTSUS.
The applicable subheading for the Pria Home Companion will be 8509.80.5095, HTSUS, which provides for electromechanical domestic appliances, with self-contained electric motor, other than vacuum cleaners of heading 8508, parts thereof: other appliances: other: other. The rate of duty will be 4.2 percent ad valorem.
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 the World Wide Web at https://hts.usitc.gov/current.
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 Michael Chen at michael.w.chen@cbp.dhs.gov.
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division
from China.
Dear Mr. Soyka:
In your letter dated September 4, 2019, you requested a tariff classification ruling.
The product under consideration is identified as the Pria Home Companion (“Pira”). It is an automated medication storage and dispensing management device. Using voice and facial recognition, the device will dispense medication. It can store up to 28 separate doses in advance, with each slot capable of holding 10 pills. Through smartphone app integration, the Pria allows a caregiver to monitor an individual’s medication and healthcare schedule. In addition to automatically dispensing medications in a timely manner, the voice and facial recognition features help prevent unauthorized access to pills contained in the Pria. A manual key pad can also be used to access medications. As an auxiliary function, the Pria will respond to a patient’s questions including about the weather, number of calories in different foods, and it will set reminders. The unit has a self-contained electric motor powered by a lithium battery. It measures approximatey 8.5 inches by 6.2 inches by 12.5 inches and weighs 4.9 lbs.
Your request states you believe the Pria Home Companion should be classified under subheading 8517.62, Harmonized Tariff Schedule of the United States (HTSUS), which provids for machines for the reception, conversion and transmission or regeneration of voice, images or other data, including switching and routing apparatus.
We disagree. While the item concerned does incorporate a data transmission/reception function, it is the opinion of this office that the data transmission/reception functionality is not the primary function of the device. The primary function of this device is to automatically dispense medication. Based on the information supplied, the item is beyond the intended scope of heading 8517, HTSUS.
The applicable subheading for the Pria Home Companion will be 8509.80.5095, HTSUS, which provides for electromechanical domestic appliances, with self-contained electric motor, other than vacuum cleaners of heading 8508, parts thereof: other appliances: other: other. The rate of duty will be 4.2 percent ad valorem.
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Janron Consult, Tax Consultant Kenya, Customs Tax Consultant Kenya, Tax Advisory Kenya
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