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Customs Ruling of the Week – Classification of Social Distancing Wristband

By Frances P. Hadfield on May 13, 2021
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In ruling HQ H316278 (March 25, 2021), Customs and Border Protection (CBP) discussed the classification of the “Proxxi Contact,” a social distancing wristband. It is designed to facilitate Covid-19 safety in offices, manufacturing facilities, and other job sites. The device “incorporates a Bluetooth transceiver and a unique identifying number that is used to detect, alert, and report interactions between individuals wearing the wristband. The fitness wristband consists of a wrist strap, top enclosure incorporating an LCD screen, a bottom enclosure, a large and small printed circuit board, and a battery.”

As explained in the ruling, the device has two primary functions: to vibrate any time that the wearer comes within six feet of another person wearing the device and to record and report each time that users come into close contact. The device will then transmit data to a back-end computer system via a Bluetooth connection to a smartphone.

CBP determined the applicable subheading for social distancing wristband is subheading 8517.62.0090, HTSUS, which provides for “Telephone sets, including telephones for cellular networks or other wireless networks; other apparatus for the transmission or reception of voice, images, or other data, including apparatus for communication in a wired or wireless network (such as a local or wide area network), other than transmission or reception apparatus of heading 8443, 8525, 8527, or 8528; parts thereof: Other apparatus for transmission or reception of voice, images or other data, including apparatus for communication in a wired or wireless network (such as a local or wide area network): machines for the reception, conversion and transmission or regeneration of voice, images or other data, including switching and routing apparatus: Other.”

The general rate of duty is Free.

Photo of Frances P. Hadfield Frances P. Hadfield

Frances P. Hadfield is a counsel in Crowell & Moring’s International Trade Group in the firm’s New York office. Her practice focuses on forced labor and withhold release orders (WRO), import regulatory compliance, and customs litigation. She regularly advises corporations on matters involving…

Frances P. Hadfield is a counsel in Crowell & Moring’s International Trade Group in the firm’s New York office. Her practice focuses on forced labor and withhold release orders (WRO), import regulatory compliance, and customs litigation. She regularly advises corporations on matters involving customs compliance, audits, customs enforcement, as well as import penalties.

Frances represents clients before the U.S. Court of International Trade and the U.S. Court of Appeals for the Federal Circuit, as well as in proceedings at the administrative level. She advises corporations on both substantive federal and state regulatory issues that involve U.S. Customs and Border Protection, the Federal Trade Commission, Food and Drug Administration, and U.S. Fish & Wildlife in matters pertaining to product admissibility, audits, classification, import restrictions, investigations, marking, licenses, origin, penalties, and tariff preference programs.

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  • Posted in:
    Privacy and Cybersecurity
  • Blog:
    International Trade Law
  • Organization:
    Crowell & Moring LLP
  • Article: View Original Source

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