June 16 CBP Bulletin Proposes to Revoke Ruling on Network Adapters
In the June 16 Customs Bulletin (Vol. 55, No. 23), CBP published a proposal to revoke and modify rulings on network adapters.
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Comments on Proposals Due July 16
CBP said consideration will be given to any written comments received by July 16 before taking these actions. In addition, any party that has received a ruling or decision on the merchandise that is subject to the proposed revocations or modifications, or any party involved with a substantially identical transaction, should advise CBP by the date that written comments on the proposed ruling are due. (An importer's failure to advise CBP of such rulings, decisions or substantially identical transactions may raise issues of reasonable care on the part of the importer or its agents for importations subsequent to the effective date of the final decision in this notice.)
Proposals
CBP is proposing to revoke or modify the rulings below, and any rulings on these products that may exist but have not been specifically identified. CBP is also proposing to revoke any treatment it has previously accorded to substantially identical transactions.
Network Adapters
| Item: Wireless network adapters |
| Current: 8517.62.0020, Free, "Telephone sets...; other apparatus for the transmission or reception of voice, images or other data...: Other apparatus for transmission or reception...: Machines for the reception, conversion, and transmission or regeneration of voice, images or other data, including switching and routing apparatus: Switching and routing apparatus." |
| Proposed: 8517.62.0090, Free, "Telephone sets...; other apparatus for the transmission or reception of voice, images or other data...: Other apparatus for transmission or reception...: Machines for the reception, conversion, and transmission or regeneration of voice, images or other data, including switching and routing apparatus: Other." |
| Reason: "Unlike a router or a switch, these network adapters have no intelligence and make no decisions as to where the data goes next," CBP said. "They do not contain a software or firmware routing table and cannot read the network address information in the data packet to determine the specific destination of the data packet. They do not physically connect individual network devices in a computer network, they only physically connect to the computer." |
| Proposed for revocation: NY N301141, dated Nov. 5, 2018 |
| Proposed new ruling: HQ H316155 |