NY N365161: RE: The tariff classification of an environmental monitoring and condition-sensing tag from Vietnam

Native CBP ruling rendition. Applicability is fact-specific; modification/revocation relationships and original publisher date are retained. Publisher sentinel year0001 means unknown date, not a historical legal adoption.

U.S. Department of Homeland Security U.S. Customs and Border Protection National Commodity Specialist Division One World Trade Center, Suite 51.201 New York, NY 10007 U.S. Customs and Border Protection N365161 September 25, 2026 CLA-2-90:OT:RR:NC:N1:105 CATEGORY: Classification TARIFF NO.: 9031.80.8085 Elena Asher Lytx, Inc. 9785 Towne Centre Drive San Diego, CA 92121 RE: The tariff classification of an environmental monitoring and condition-sensing tag from Vietnam Dear Ms. Asher: In your letter dated September 16, 2026, you requested a tariff classification ruling. Descriptive literature was provided for our review. The item under consideration is described as the SD-D05 (A·TRACS), which is a composite, self-contained, battery-powered electronic sensor tag enclosed in a compact plastic housing. It is designed primarily as a wireless environmental-monitoring and condition-sensing tag for utilization in transportation, logistics, and supply-chain asset management. The device incorporates an array of integrated micro-sensors engineered to measure, log, and monitor ambient environmental criteria (including temperature, relative humidity, light exposure, and tri-axial acceleration (shock/tilt)) to verify the structural and thermal integrity of commercial cargo during transit. Data acquisition is managed by an internal microcontroller that automatically cross-references environmental measurements against user-defined safety thresholds. The device features a short-range wireless Bluetooth communication transmitter that transmits recorded telemetry, real-time status alerts, and historical data logs to external gateway receivers, handheld mobile terminals, or centralized cloud networks. In your submission, you suggest that the SD-D05 environmental sensor tag is classified under subheading 8526.91.0040, Harmonized Tariff Schedule of the United States (HTSUS), as radio navigational aid apparatus. However, the information provided states that it does not contain a GPS/GNSS receiver, or other radio-navigation or radio-remote-control apparatus. Since that is the case, classification in heading 8526, HTSUS, is not applicable. Furthermore, when an accelerometer is built into an environmental logger to register shock, vibration, or impact events alongside temperature/humidity, the instrument’s essential character is no longer just a thermometer/hygrometer. It acts as a comprehensive physical tracking and checking unit covered by heading 9031, HTSUS.
The applicable subheading for the SD-D05 (A·TRACS) will be 9031.80.8085, HTSUS, which provides for 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: Other.” The general rate of duty will be free. The duties cited above are current as of this ruling’s issuance. 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 at https://hts.usitc.gov/. This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the classification stated above, the merchandise covered by this ruling may also need to be reported with either the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions covering exceptions to such tariffs. For further information to assist with the importation process, please refer to the frequently updated Cargo Systems Messaging Service (CSMS) messages at https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and the Trade Remedies page at https://www.cbp.gov/trade/programs-administration/trade-remedies. The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection 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, please contact National Import Specialist Jason Christie at jason.m.christie@cbp.dhs.gov. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division