WEBVTT 00:00:19.447 --> 00:00:20.264 >> 00:00:00.000 --> 00:00:30.830 00:00:20.265 --> 00:00:24.158 >> Good morning, everyone this is Jason Christie Umm or afternoon, 00:00:24.159 --> 00:00:27.119 depending on where you're located if you're on the West Coast. 00:00:27.120 --> 00:00:28.480 So my name 's Jason Christie. 00:00:28.480 --> 00:00:31.390 I am part of the office of NIS 105 00:00:31.390 --> 00:00:35.960 along with national imports specialist associate John Vischio. 00:00:35.960 --> 00:00:39.240 So John 's been with us for about a year now and we are definitely welcome 00:00:39.240 --> 00:00:40.140 to have him. 00:00:40.140 --> 00:00:41.920 He's not here today because he's attending 00:00:41.920 --> 00:00:45.480 the basic import Specialist Training Academy in Charleston, South Carolina. 00:00:45.480 --> 00:00:48.640 I believe that class just started today as well. 00:00:48.640 --> 00:00:51.180 He's stationed at the World Trade Center in New York City. 00:00:51.180 --> 00:00:52.570 >> 00:00:30.900 --> 00:01:03.660 00:00:52.586 --> 00:00:55.396 >> Which has a fantastic view if you're able to uh to go there 00:00:56.399 --> 00:00:57.789 as you can see from the screen today. 00:00:57.790 --> 00:01:01.210 We are gonna be discussing various instruments of heading 9025, 00:01:01.210 --> 00:01:05.480 including thermometers, which have been the hot topic because of the COVID. 00:01:05.480 --> 00:01:08.390 This will include making you familiar with the tariff subheadings. 00:01:08.390 --> 00:01:12.530 What belongs in 9025 and then a couple things that are a couple of items 00:01:12.530 --> 00:01:16.540 that are not there are several chapter notes and explanatory notes 00:01:16.540 --> 00:01:19.840 that we'll discuss which will help aid you in classifying these products 00:01:19.840 --> 00:01:22.770 and you will notice some of the subheadings are very straightforward 00:01:22.770 --> 00:01:23.720 and very easy to classify. 00:01:23.720 --> 00:01:25.980 >> 00:01:03.740 --> 00:01:05.600 >> And others will be not so much. 00:01:25.980 --> 00:01:29.067 >> 00:01:08.680 --> 00:01:39.550 00:01:29.067 --> 00:01:32.640 >> So, just before I begin I'll just introduce myself a little bit further. 00:01:32.640 --> 00:01:34.170 I'm stationed in Buffalo, New York. 00:01:34.170 --> 00:01:39.780 So I'm one of the remote NIST and started my customs career in 2003. 00:01:39.780 --> 00:01:41.800 So I went through the typical career path 00:01:41.800 --> 00:01:45.690 of import specialist senior import specialist supervisory import specialist 00:01:45.690 --> 00:01:48.980 and then did a little stint as the acting Assistant Center director 00:01:48.980 --> 00:01:51.420 with the industrial and manufacturing materials center. 00:01:51.420 --> 00:01:54.267 But before ultimately becoming a national import specialist 00:01:54.267 --> 00:01:56.473 about 3 years ago, so I've already spoken 00:01:56.474 --> 00:01:58.195 with many of you in the machinery center. 00:01:58.217 --> 00:02:00.439 >> 00:01:39.910 --> 00:02:12.060 00:02:00.440 --> 00:02:02.755 >> Uh, which is where a lot of my tariffs lie uh 00:02:02.756 --> 00:02:04.030 but I've also speak spoken 00:02:04.030 --> 00:02:07.010 with many uh people in the trade community as well. 00:02:07.010 --> 00:02:10.600 I continue to welcome those conversations and I hope I've helped 00:02:10.600 --> 00:02:14.610 with everything that I've discussed with you as you can see from the slide. 00:02:14.610 --> 00:02:17.930 That's currently up my tariff provisions are mostly in chapter 90 00:02:17.930 --> 00:02:18.850 with just a few headings. 00:02:18.850 --> 00:02:21.350 In Chapter 84, so in 84. 00:02:21.350 --> 00:02:23.440 I mostly end up seeing issues with the filters. 00:02:23.440 --> 00:02:28.770 In 8421 and the spraying apparatus and 84241 of the hot topics. 00:02:28.770 --> 00:02:32.267 In Chapter 90, has been the thermometers due to COVID like I was saying before. 00:02:32.267 --> 00:02:32.800 >> 00:02:12.260 --> 00:02:18.550 00:02:32.800 --> 00:02:35.520 >> And due to the recent change to the tariff in in 9025. 00:02:35.520 --> 00:02:37.867 I thought this would be a good time to kind of run through everything 00:02:37.867 --> 00:02:38.933 with the heading. 00:02:38.933 --> 00:02:42.267 >> 00:02:21.910 --> 00:02:35.100 00:02:42.267 --> 00:02:44.990 >> So before we jump into the rest of the presentation 00:02:44.990 --> 00:02:48.410 just a few housekeeping slides before we get the get started. 00:02:48.410 --> 00:02:50.560 So this slide just shows our mission statement, 00:02:50.560 --> 00:02:53.020 so protect the American people safeguard our borders 00:02:53.020 --> 00:02:55.533 and enhance the nation 's economic prosperity. 00:02:55.533 --> 00:02:58.734 >> 00:02:38.450 --> 00:02:49.960 00:02:58.734 --> 00:03:01.790 >> We switched our webinars series this year to teams, 00:03:01.790 --> 00:03:04.780 so this slide just shows some of the features that are available in teams 00:03:04.780 --> 00:03:08.250 in case you were unaware so most of the features are obtained 00:03:08.250 --> 00:03:10.533 by the top menu, including the chat box. 00:03:10.533 --> 00:03:11.333 >> 00:02:51.080 --> 00:03:07.850 00:03:11.333 --> 00:03:15.330 >> Uh raising your hand and lowering your hand and the 3 dots 00:03:15.330 --> 00:03:16.475 so the menu that drops down 00:03:16.476 --> 00:03:18.680 after hitting the 3 dots will give you the ability 00:03:18.680 --> 00:03:22.340 to make the screen larger as well as turn on the live captions 00:03:22.340 --> 00:03:25.220 to shrink your screen back down or turn off the captions. 00:03:25.220 --> 00:03:27.801 You could just go back to the the 3 dots and and select that. 00:03:27.802 --> 00:03:29.132 >> 00:03:08.640 --> 00:03:40.010 00:03:29.133 --> 00:03:30.922 >> I'm gonna ask you to save your questions 00:03:30.923 --> 00:03:32.910 until the end of the presentation 00:03:32.910 --> 00:03:35.020 and if you do have something that you would like 00:03:35.020 --> 00:03:36.470 to ask during the presentations. 00:03:36.470 --> 00:03:39.070 You can type it into the checkbox either. 00:03:39.070 --> 00:03:42.730 Miriam or Fung will be monitoring the chat box and making you aware 00:03:42.730 --> 00:03:46.190 of any additional items that I should be aware of also note that 00:03:46.190 --> 00:03:49.590 if you want to ask any additional questions after the presentation. 00:03:49.590 --> 00:03:51.270 Feel free to also send me an email. 00:03:51.270 --> 00:03:53.890 I'm the very first slide and on the last slide. 00:03:53.890 --> 00:03:56.154 I provided some of my contact information, 00:03:56.155 --> 00:03:58.050 so that's a great way to get a hold 00:03:58.050 --> 00:04:00.067 of me is sending me an email and then we can dusk. 00:04:00.067 --> 00:04:00.231 >> 00:03:40.080 --> 00:03:42.140 00:04:00.231 --> 00:04:02.567 >> Discuss whatever you have a little bit further. 00:04:02.567 --> 00:04:10.867 >> 00:03:50.230 --> 00:04:04.510 00:04:10.867 --> 00:04:13.640 >> So this slide is just a reminder that our binding rulings program 00:04:13.640 --> 00:04:17.040 is a great way to get an official classification for your product, 00:04:17.040 --> 00:04:19.130 the E rulings program has made it very easy 00:04:19.130 --> 00:04:22.500 to submit your binding rulings and our new system on the CBP side 00:04:22.500 --> 00:04:24.150 of the House makes it very easily to. 00:04:24.150 --> 00:04:26.950 >> 00:04:05.420 --> 00:04:06.530 >> To not only. 00:04:26.950 --> 00:04:27.620 >> 00:04:09.490 --> 00:04:13.290 00:04:29.833 --> 00:04:32.110 >> But OK I was just wondering if with the chat box 00:04:32.110 --> 00:04:33.867 if there was some issues going on there. 00:04:33.867 --> 00:04:35.533 >> 00:04:14.000 --> 00:04:14.290 >> Right. 00:04:35.533 --> 00:04:38.560 >> 00:04:15.190 --> 00:04:48.760 >> So once you request a ruling. 00:04:38.560 --> 00:04:41.540 It's usually put into the customs ruling online search system or cross 00:04:41.540 --> 00:04:47.110 for everyone to see and CSD rulings are consistently made within 30 days. 00:04:47.110 --> 00:04:50.810 I it's very rare if any of the the rulings do go beyond 30 days. 00:04:50.810 --> 00:04:53.800 I know sometimes we do have to reject or ask additional questions 00:04:53.800 --> 00:04:55.040 or things like that. 00:04:55.040 --> 00:04:59.830 But overall, you know, we, we try to get those out in 30 days. 00:04:59.830 --> 00:05:03.210 The cross system also helps with the research of classification, 00:05:03.210 --> 00:05:06.890 but again don't rely solely on cross to classify your merchandise, 00:05:06.890 --> 00:05:08.470 most of the time you won't see an exact product. 00:05:08.470 --> 00:05:09.860 >> 00:04:48.870 --> 00:05:00.360 00:05:09.860 --> 00:05:12.160 >> That's listed in the ruling, which means that there could be nuances 00:05:12.160 --> 00:05:15.660 that make the situation different in the ruling that might be in cross 00:05:15.660 --> 00:05:19.180 and what you might have in front of you so always use reasonable care 00:05:19.180 --> 00:05:20.850 when classifying your merchandise. 00:05:20.850 --> 00:05:25.805 >> 00:05:05.460 --> 00:05:29.270 00:05:25.805 --> 00:05:28.890 >> Speaking of reasonable care this disclaimer is essentially saying 00:05:28.890 --> 00:05:31.830 that the presentation is for informational purposes only 00:05:31.830 --> 00:05:35.660 and that it should not be relied on for specific classification purposes. 00:05:35.660 --> 00:05:38.270 Every product is different and speaking with the customs expert 00:05:38.270 --> 00:05:42.410 such as a broker trade attorney or customs official is the best way 00:05:42.410 --> 00:05:45.680 to ensure that you're going to have proper reasonable care. 00:05:45.680 --> 00:05:47.840 And remember that the binding ruling program is a great way 00:05:47.840 --> 00:05:49.670 to ensure your classification is correct. 00:05:49.670 --> 00:05:54.533 >> 00:05:34.210 --> 00:06:01.000 00:05:54.533 --> 00:05:58.760 >> Also, the images that we end up using for this presentation are 00:05:58.760 --> 00:06:01.230 either obtained from rulings or from the Internet and are 00:06:01.230 --> 00:06:03.210 for educational purposes only. 00:06:03.210 --> 00:06:05.270 We do not endorse any of the products that are pictured 00:06:05.270 --> 00:06:07.160 in the webinar whenever possible. 00:06:07.160 --> 00:06:10.700 We like to add pictures just to show a quick example of what the product 00:06:10.700 --> 00:06:15.780 might be like or if you know if we're trying to explain a certain product. 00:06:15.780 --> 00:06:19.600 The exact product that we are explaining might not be what's on the slide, 00:06:19.600 --> 00:06:21.800 but it's a close representation. 00:07:37.622 --> 00:07:38.644 >> 00:07:18.370 --> 00:07:25.820 00:07:38.645 --> 00:07:42.417 >> This is followed by the other instruments in 192580 00:07:42.417 --> 00:07:46.300 and then finally we have the parts and accessories provision in 192590. 00:07:46.300 --> 00:07:53.900 >> 00:07:37.330 --> 00:08:10.580 00:07:55.898 --> 00:08:00.349 >> A thermometer is a device that measures temperature 00:08:00.350 --> 00:08:03.300 or a temperature gradient pretty much the degree of hotness 00:08:03.300 --> 00:08:07.590 or coldness of an object a thermometer has 2 important elements. 00:08:07.590 --> 00:08:10.110 The first one being a temperature sensor. 00:08:10.110 --> 00:08:13.800 This could for example, be a bulb of mercury and a glass thermometer 00:08:13.800 --> 00:08:18.040 or a pyrometric sensor and an infrared thermometer in which some sort 00:08:18.040 --> 00:08:20.640 of change occurs with a change in temperature 00:08:20.640 --> 00:08:23.890 and then it would also need a some means of converting this change 00:08:23.890 --> 00:08:28.670 into a numerical value so for example, there's a visible scale 00:08:28.670 --> 00:08:31.080 that is marked on a Mercury in glass thermometer. 00:08:31.080 --> 00:08:31.267 >> 00:08:10.780 --> 00:08:13.370 00:08:31.267 --> 00:08:33.767 >> Or the the digital readout on an infrared model. 00:08:33.767 --> 00:08:41.160 >> 00:08:20.770 --> 00:08:51.310 00:08:41.160 --> 00:08:44.733 >> We start off with the liquid filled thermometers for direct reading 00:08:44.733 --> 00:08:48.660 so these are not electronic which is typically meaning battery or plug in 00:08:48.660 --> 00:08:50.290 and works based on the principle of heating 00:08:50.290 --> 00:08:55.120 and cooling a liquid typically typically a liquid that can be measured 00:08:55.120 --> 00:08:57.810 by looking at the reading of on the device. 00:08:57.810 --> 00:09:03.730 The thermometers are broken down by 902511, 2000 for clinical and 902511, 00:09:03.730 --> 00:09:05.750 4000 for nonclinical. 00:09:05.750 --> 00:09:07.380 As I'll explain later. 00:09:07.380 --> 00:09:08.870 The Differentiation is made between 00:09:08.871 --> 00:09:11.680 whether the device will be used for human or animal use. 00:09:11.680 --> 00:09:11.867 >> 00:08:51.560 --> 00:08:57.550 00:09:11.867 --> 00:09:14.670 >> That's the clinical type or whether it is used 00:09:14.670 --> 00:09:18.000 for other items like a a candy thermometer as an example. 00:09:18.000 --> 00:09:19.554 >> 00:08:59.260 --> 00:09:06.130 00:09:19.554 --> 00:09:21.970 >> I'll repeat this concept definitely throughout the presentation 00:09:21.970 --> 00:09:24.729 as it is a big factor to keep in mind, and relatively new clarification 00:09:24.745 --> 00:09:25.050 to the tariff. 00:09:25.050 --> 00:09:26.510 >> 00:09:06.770 --> 00:09:13.910 00:09:27.233 --> 00:09:30.030 >> The picture on the left is the traditional white plastic thermometer 00:09:30.030 --> 00:09:32.940 and the one on the right is thermometer resting in a pot of boiling liquid? 00:09:32.940 --> 00:09:40.254 >> 00:09:19.740 --> 00:09:51.410 00:09:40.254 --> 00:09:44.130 >> So quickly looking at the explanatory notes so glass thermometers 00:09:44.130 --> 00:09:46.400 with the liquid filled glass tube. 00:09:46.400 --> 00:09:49.000 These include household thermometers room window thermometers. 00:09:49.000 --> 00:09:51.670 Etcetera floating thermometers bath thermometers. 00:09:51.670 --> 00:09:53.910 Etcetera clinical thermometers. 00:09:53.910 --> 00:09:56.170 Industrial thermometers for boilers furnaces 00:09:56.170 --> 00:10:00.480 and autoclaves laboratory thermometers used in killer imagery. 00:10:00.480 --> 00:10:04.050 Special meteorological thermometers for for measuring solar 00:10:04.050 --> 00:10:06.890 or terrestrial radiations thermometers used 00:10:06.890 --> 00:10:11.150 in hydrophilic reversible thermometers used in taking deep sea soundings. 00:10:11.150 --> 00:10:12.790 >> 00:09:51.610 --> 00:09:59.900 00:10:12.790 --> 00:10:14.740 >> Uh the heading also includes glass thermometers called minimum 00:10:14.740 --> 00:10:18.230 and maximum thermometers since they are designed to indicate the highest 00:10:18.230 --> 00:10:19.400 and lowest temperature they have recorded. 00:10:19.400 --> 00:10:20.740 >> 00:10:01.040 --> 00:10:10.490 00:10:20.740 --> 00:10:23.910 >> So that just gives a little insight into what the Explanatory. 00:10:23.910 --> 00:10:27.410 Note say, and which as you know are non binding, 00:10:27.410 --> 00:10:28.970 but are definitely a great resource when you're trying 00:10:28.970 --> 00:10:29.750 to classify your merchandise. 00:10:29.750 --> 00:10:31.430 >> 00:10:11.520 --> 00:10:13.710 00:10:31.430 --> 00:10:33.790 >> So definitely keep your explanatory notes in mind. 00:10:33.790 --> 00:10:38.867 >> 00:10:18.460 --> 00:10:46.250 00:10:38.867 --> 00:10:41.120 >> So as I was saying the most important thing to take away 00:10:41.120 --> 00:10:44.440 from this presentation is the ability to differentiate between clinical 00:10:44.440 --> 00:10:48.640 and nonclinical so clinical is for human and animal use. 00:10:48.640 --> 00:10:51.180 So when you were taking your child 's temperature before kicking them off 00:10:51.180 --> 00:10:53.660 to school that would be considered a clinical thermometer 00:10:53.661 --> 00:10:54.600 since it's being used 00:10:54.600 --> 00:10:57.040 on your child or if you feel that you have a temperature 00:10:57.040 --> 00:10:59.220 and you would just like to take your reading that would be 00:10:59.220 --> 00:11:00.830 on a clinical thermometer. 00:11:00.830 --> 00:11:02.750 If you're sticking the thermometer into food, 00:11:02.750 --> 00:11:05.160 then that would be considered a non clinical thermometer 00:11:05.162 --> 00:11:06.710 because it's for other uses. 00:11:10.149 --> 00:11:11.729 >> 00:10:49.770 --> 00:10:59.020 00:11:11.730 --> 00:11:13.390 >> We also ended up putting a few other examples on the slide 00:11:13.390 --> 00:11:14.370 just as an example. 00:11:14.370 --> 00:11:16.070 Like Uh, an oven or a room or a a window thermometer 00:11:16.070 --> 00:11:17.050 would be considered nonclinical. 00:11:17.050 --> 00:11:18.920 >> 00:11:01.090 --> 00:11:27.300 00:11:21.500 --> 00:11:23.880 >> This concept is further clarified in the tariff, 00:11:23.880 --> 00:11:26.850 which is now under Chapter 90 statistical. 00:11:26.850 --> 00:11:32.940 Note 2, so for the purposes of statistical reporting number 9025198010 00:11:32.940 --> 00:11:35.620 clinical infrared thermometers are devices designed for use 00:11:35.620 --> 00:11:37.630 to check the body temperature of humans and animals 00:11:37.630 --> 00:11:43.080 so while this note directly relates to 9025198010, which will be coming later. 00:11:43.080 --> 00:11:46.450 We have definitely expanded the concept to the the concept 00:11:46.450 --> 00:11:47.800 throughout the heading. 00:11:47.800 --> 00:11:53.400 >> 00:11:32.960 --> 00:12:02.410 00:11:53.400 --> 00:11:57.860 >> The 192519 4000, is other thermometers for example, a pyrometer. 00:11:57.860 --> 00:12:00.730 This is a device for measuring relatively high temperatures, 00:12:00.730 --> 00:12:02.840 such as we encounter in furnaces. 00:12:02.840 --> 00:12:04.828 Most parameters work by measuring radiation 00:12:04.829 --> 00:12:06.410 from the body whose temperature is 00:12:06.410 --> 00:12:10.640 to be measured radiation does have an advantage of not having 00:12:10.640 --> 00:12:14.050 to touch the material being measured optical pyrometers, 00:12:14.050 --> 00:12:15.343 which can also be known 00:12:15.344 --> 00:12:18.210 as like brightness parameters measure temperature 00:12:18.210 --> 00:12:19.084 in the visible light spectrum 00:12:19.085 --> 00:12:20.560 while infrared thermometers measure temperature 00:12:20.560 --> 00:12:22.600 and the infrared light spectrum. 00:12:22.600 --> 00:12:23.570 >> 00:12:03.320 --> 00:12:25.070 00:12:23.571 --> 00:12:25.470 >> So essentially a parameter is an instrument 00:12:25.470 --> 00:12:28.340 that measures temperature remotely by measuring radiation 00:12:28.340 --> 00:12:31.500 from the object without having to be in contact 00:12:31.500 --> 00:12:33.000 from the classification perspective. 00:12:33.000 --> 00:12:34.870 Every time that I've seen a parameter in the field. 00:12:34.870 --> 00:12:39.210 It's been clearly named a parameter and it's function was was clear just based 00:12:39.210 --> 00:12:41.850 on the information that I was provided so this is one 00:12:41.850 --> 00:12:45.867 of the typically easier devices to classify. 00:12:45.867 --> 00:12:50.467 >> 00:12:30.100 --> 00:12:55.650 00:12:50.467 --> 00:12:53.190 >> 9025198010. 00:12:53.190 --> 00:12:56.420 So this is the clinical infrared thermometer of a kind described 00:12:56.420 --> 00:12:59.090 in statistical Note 2 of this chapter so used 00:12:59.090 --> 00:13:02.500 to check the temperature the body temperatures of humans and animals. 00:13:02.500 --> 00:13:04.290 These are the thermometers pictured on the left 00:13:04.291 --> 00:13:05.520 where you have a few inches away 00:13:05.520 --> 00:13:08.440 from the patient and when you push a trigger or a button, it shoots. 00:13:08.440 --> 00:13:12.100 The infrared beam into the forehead and then provides a temperature reading 00:13:12.100 --> 00:13:13.240 of some sort. 00:13:13.240 --> 00:13:16.000 These are very common, especially now with the COVID-19 room. 00:13:16.000 --> 00:13:18.067 >> 00:12:57.660 --> 00:13:14.780 00:13:18.067 --> 00:13:24.270 >> And then we have 9025198020 so these are other than clinical thermometers, 00:13:24.270 --> 00:13:28.550 so non infrared thermometers, not described in statistical Note 2 00:13:28.550 --> 00:13:29.680 of this chapter. 00:13:29.680 --> 00:13:32.390 These are commonly referred to as stick thermometers, 00:13:32.390 --> 00:13:35.200 so these thermometers are used under the tongue or anally. 00:13:35.200 --> 00:13:35.680 >> 00:13:15.590 --> 00:13:19.740 00:13:35.680 --> 00:13:38.260 >> For both types of thermometers, they run off batteries 00:13:38.260 --> 00:13:40.200 or plugged in which is less common. 00:13:40.200 --> 00:13:47.458 >> 00:13:27.090 --> 00:13:40.970 00:13:47.458 --> 00:13:52.360 >> The 1925198060 so this is other infrared thermometers, 00:13:52.360 --> 00:13:55.970 so these are infrared thermometers that are not used for humans or animals. 00:13:55.970 --> 00:13:58.490 These examples that we have here as an infrared thermometer. 00:13:58.490 --> 00:14:01.660 That's used to check the air temperature coming out of heating Ducks. 00:14:01.660 --> 00:14:03.133 >> 00:13:42.860 --> 00:13:54.410 00:14:03.133 --> 00:14:08.420 >> And then we have 9025198085, which is other other these are devices 00:14:08.420 --> 00:14:10.790 that are used in electrical means but to operate, 00:14:10.790 --> 00:14:14.995 but are not infrared the orange example on the right is a meat thermometer. 00:14:14.995 --> 00:14:24.511 >> 00:14:04.110 --> 00:14:21.060 00:14:24.511 --> 00:14:28.140 >> So 902580, 1000, so when you start getting into 80. 00:14:28.140 --> 00:14:31.440 You're getting into the other instruments so 81,000. 00:14:31.440 --> 00:14:34.100 These are electrical instruments described in the heading they 00:14:34.100 --> 00:14:37.060 they can be combined with other multiple instruments. 00:14:37.060 --> 00:14:37.630 So many times. 00:14:37.630 --> 00:14:41.650 We might see thermometers mixed in with items like hydrometers or hydrometers. 00:14:41.650 --> 00:14:43.133 >> 00:14:22.740 --> 00:14:35.030 00:14:43.133 --> 00:14:46.450 >> When looking through cross you'll notice that there's several rulings. 00:14:46.450 --> 00:14:50.960 They're quite a few rulings actually that are classified in 902580, 1000. 00:14:50.960 --> 00:14:53.650 It's a very common classification when you have multiple 00:14:53.650 --> 00:14:55.467 electronic devices combined. 00:14:55.467 --> 00:14:58.600 >> 00:14:38.110 --> 00:14:41.900 00:14:58.600 --> 00:15:02.267 >> So looking at Chapter 90 additional US Note 2. 00:15:02.267 --> 00:15:03.533 >> 00:14:43.070 --> 00:15:15.200 >> So for the purposes of this chapter. 00:15:03.533 --> 00:15:08.112 The term electrical when used in reference 00:15:08.113 --> 00:15:10.600 to instruments appliances apparatus 00:15:10.600 --> 00:15:13.140 and machines refers to the articles. 00:15:13.140 --> 00:15:16.150 The operation of which depends on an electrical phenomenon, 00:15:16.150 --> 00:15:19.070 which varies according to the factor to be ascertained 00:15:19.070 --> 00:15:21.219 so like I stated earlier electrical typically 00:15:21.220 --> 00:15:24.010 ends up meaning battery operated or plugged into an outlet. 00:15:24.010 --> 00:15:24.930 But as you'll see later. 00:15:24.930 --> 00:15:28.710 There's there's a few additional examples out there that are something 00:15:28.710 --> 00:15:32.860 other than battery operated or plugged in mostly when it comes 00:15:32.860 --> 00:15:33.610 to the thermometers. 00:15:33.610 --> 00:15:36.170 You'll you'll see a lot of battery operated ones. 00:15:36.170 --> 00:15:42.074 >> 00:15:21.880 --> 00:15:52.690 00:15:42.074 --> 00:15:45.533 >> And like I mentioned there's a lot of rulings that place different items. 00:15:45.533 --> 00:15:47.380 In 192580, 1000 and this slide. 00:15:47.380 --> 00:15:49.940 I've just provided a few examples on that. 00:15:49.940 --> 00:15:55.760 CBP has classified in 192580, 1000, so for example, N 304500 is 00:15:55.760 --> 00:15:59.910 in viral probe monitors temperature and humidity and relays the information back 00:15:59.910 --> 00:16:05.830 to the data center and then in the second one and 297239 from 2018. 00:16:05.830 --> 00:16:07.960 That's a module that measures the temperature humidity, 00:16:07.960 --> 00:16:13.000 and carbon dioxide concentration and then in nym 82227. 00:16:13.000 --> 00:16:13.280 >> 00:15:52.850 --> 00:16:01.240 00:16:13.280 --> 00:16:16.480 >> From 2006 that was a frog shaped moisture meter, 00:16:16.480 --> 00:16:19.900 which has a dark a dial marked in a subdivision of one to 10, 00:16:19.900 --> 00:16:21.910 indicating measurement from dry to wet. 00:16:21.910 --> 00:16:23.200 >> 00:16:02.850 --> 00:16:07.420 00:16:23.200 --> 00:16:27.500 >> So, just a few different examples, uh historically of some new ones 00:16:27.500 --> 00:16:27.928 that we've had. 00:16:27.928 --> 00:16:31.119 >> 00:16:10.900 --> 00:16:41.230 00:16:31.119 --> 00:16:35.530 >> So now, what we do is we get into the non electrical instruments. 00:16:35.530 --> 00:16:42.460 So 9025851500 is for barometers, not combined with other instruments. 00:16:42.460 --> 00:16:44.540 So what does a barometer so these are instruments 00:16:44.540 --> 00:16:48.650 for determining the atmospheric pressure these parameters are not combined 00:16:48.650 --> 00:16:51.820 with other instruments and many barometers will be filled with mercury 00:16:51.820 --> 00:16:55.630 and the atmospheric pressure will push down on one side and lift the Mercury 00:16:55.630 --> 00:16:58.193 to a certain level measured in millimeters, 00:16:58.193 --> 00:17:01.400 so these are typically dashes and numbers written on the glass tube. 00:17:01.400 --> 00:17:01.800 >> 00:16:41.300 --> 00:16:44.870 00:17:01.800 --> 00:17:05.367 >> Containing the mercury an example is of the picture on the left. 00:17:05.367 --> 00:17:06.556 >> 00:16:46.180 --> 00:16:54.970 00:17:06.556 --> 00:17:09.511 >> Other types of barometers are like the one that you see on the right 00:17:09.511 --> 00:17:13.700 where the the pressure pushes on the internal components of around disk 00:17:13.700 --> 00:17:15.700 and provides the the reading on the face. 00:17:15.701 --> 00:17:21.902 >> 00:22:45.390 --> 00:22:57.940 00:23:05.796 --> 00:23:08.169 >> Right and then we have chapter 90 Note 2, 00:23:08.169 --> 00:23:10.367 so subject to note one above parts 00:23:10.367 --> 00:23:13.833 and accessories for machines apparatus instruments and articles 00:23:13.833 --> 00:23:16.567 of this chapter are to be classified according to the following rules 00:23:16.567 --> 00:23:18.967 and then there's the A The B and the C. 00:23:18.967 --> 00:23:19.123 >> 00:22:58.600 --> 00:23:05.970 00:23:19.123 --> 00:23:22.033 >> So A is parts and accessories, which are goods included 00:23:22.033 --> 00:23:26.233 in any of the headings of this chapter or chapter 8485 or 91. 00:23:26.233 --> 00:23:27.367 >> 00:23:06.760 --> 00:23:13.060 00:23:27.367 --> 00:23:31.833 >> Other than heading 84878548 or 9033 are in all cases to be classified 00:23:31.833 --> 00:23:33.767 in their respective headings. 00:23:33.767 --> 00:23:34.108 >> 00:23:13.680 --> 00:23:33.680 00:23:34.108 --> 00:23:38.433 >> And then B other parts and accessories of suitable for use solely 00:23:38.433 --> 00:23:41.900 or principally with a particular kind of machine instrument or apparatus 00:23:41.900 --> 00:23:45.300 or with the number of machines instruments or apparatus 00:23:45.300 --> 00:23:48.033 at the same heading including the machine instrument 00:23:48.033 --> 00:23:51.700 or apparatus petting 90109013 or 1931 are to be classified 00:23:51.700 --> 00:23:53.900 with the machines instruments or apparatus of that kind. 00:23:53.900 --> 00:23:55.567 >> 00:23:35.150 --> 00:23:48.160 00:23:55.567 --> 00:23:59.767 >> And then part C, which is one that we don't usually get down to. 00:23:59.767 --> 00:24:04.033 I've I've seen it on a couple of instances, but usually A or B takes care 00:24:04.033 --> 00:24:04.979 of it when it comes to parts. 00:24:04.979 --> 00:24:08.533 But all other parts and accessories are to be classified and heading 9033. 00:24:08.533 --> 00:24:16.072 >> 00:23:55.770 --> 00:24:00.240 00:24:16.073 --> 00:24:19.942 >> And then just to point out a couple more chapter 90 keynotes 00:24:19.942 --> 00:24:20.672 that we have out there. 00:24:20.672 --> 00:24:21.573 >> 00:24:01.190 --> 00:24:19.000 00:24:21.573 --> 00:24:27.633 >> So one F in one K so one F is for parts of general use 00:24:27.633 --> 00:24:29.822 as defined in Note 2 of section. 00:24:29.832 --> 00:24:34.499 XB of base metals and section XV or similar goods of plastic of Chapter 39 00:24:34.500 --> 00:24:39.367 and then one K which states articles of Chapter 95. 00:24:39.367 --> 00:24:39.900 >> 00:24:19.610 --> 00:24:25.420 >> So essentially if you have plain screws. 00:24:39.900 --> 00:24:44.767 This will not be considered a part of a thermometer they would stay classified 00:24:44.767 --> 00:24:45.833 as a screw. 00:24:45.833 --> 00:24:46.900 >> 00:24:26.450 --> 00:24:32.810 00:24:46.900 --> 00:24:51.433 >> For one K if you have a clearly defined article of Chapter 95 00:24:51.433 --> 00:24:53.433 such as sporting equipment that is uh. 00:24:53.433 --> 00:24:54.433 >> 00:24:33.920 --> 00:25:05.110 00:24:54.433 --> 00:24:59.167 >> As as long that has a small thermometer or barometer or a device 00:24:59.167 --> 00:25:01.300 that could be considered sporting equipment. 00:25:01.300 --> 00:25:02.167 As long as it can fully function. 00:25:02.167 --> 00:25:06.833 Umm what I've seen here is just as an example of a Golf Club 00:25:06.833 --> 00:25:09.767 with a small thermometer still operates as a Golf Club 00:25:09.767 --> 00:25:13.033 and would be eliminated from heading 9025 by note. 00:25:13.033 --> 00:25:16.433 One K so I've I've seen golf clubs that end up having 00:25:16.433 --> 00:25:18.833 just that little thermometer on it in that case. 00:25:18.833 --> 00:25:23.167 The thermometer wouldn't be equal consideration or anything like that, 00:25:23.167 --> 00:25:26.033 it, it's it can still function completely as a Golf Club. 00:25:26.033 --> 00:25:27.833 >> 00:25:05.180 --> 00:25:07.100 >> With or without that thermometer on there. 00:25:27.833 --> 00:25:34.033 >> 00:25:13.740 --> 00:25:38.150 00:25:34.033 --> 00:25:38.500 >> So additional US Note 2, so for the purposes of this chapter. 00:25:38.500 --> 00:25:41.167 The term electrical when used in reference 00:25:41.167 --> 00:25:44.833 to the instruments appliances apparatus and machines reverse to those articles. 00:25:44.833 --> 00:25:47.833 The operation of which depends on an electrical phenomenon, 00:25:47.833 --> 00:25:51.900 which varies according to the factors to be ascertained so for our purposes. 00:25:51.900 --> 00:25:54.967 This mostly ends up meaning battery operated or plugged in 00:25:54.967 --> 00:25:58.833 but as you'll see later there's a few different interpretations of electrical. 00:26:00.233 --> 00:26:02.700 >> 00:25:39.840 --> 00:25:42.180 >> And then we also have statistical Note 2. 00:26:02.700 --> 00:26:03.172 >> 00:25:42.830 --> 00:26:01.330 00:26:03.172 --> 00:26:08.300 >> So for the purposes of statistical reporting number 9025198010 00:26:08.300 --> 00:26:10.367 clinical infrared thermometers are designed 00:26:10.367 --> 00:26:12.767 our device is designed to be used 00:26:12.767 --> 00:26:15.900 to check the body temperatures of humans and animals and this one. 00:26:15.900 --> 00:26:17.767 We touched on earlier, but it's important 00:26:17.767 --> 00:26:19.700 to add just note that it's now added 00:26:19.700 --> 00:26:21.700 to the tariff as of July of 2020. 00:26:21.700 --> 00:26:28.479 >> 00:26:08.200 --> 00:26:11.660 00:26:28.479 --> 00:26:32.199 >> So just to highlight a few of the the 9025 key points. 00:26:32.200 --> 00:26:32.602 >> 00:26:12.300 --> 00:26:34.530 00:26:32.603 --> 00:26:36.130 >> So we have clinical versus non clinical thermometers. 00:26:36.130 --> 00:26:39.360 We have infrared versus non infrared thermometers. 00:26:39.360 --> 00:26:42.220 We have electrical versus non electrical 00:26:42.220 --> 00:26:45.480 and then we have recording versus non recording instruments. 00:26:45.480 --> 00:26:48.370 So hopefully just going through some of those different provisions 00:26:48.370 --> 00:26:50.520 and kind of explaining it out a little bit, it kind of brings 00:26:50.520 --> 00:26:53.200 to light some of the the differences between the 2 there 00:26:53.200 --> 00:26:54.933 or the difference between the 4 there. 00:26:54.933 --> 00:26:57.169 >> 00:26:36.710 --> 00:26:47.350 00:26:57.170 --> 00:26:59.470 >> And then we also have a few key rulings that we're going over 00:26:59.470 --> 00:27:01.130 in a little bit more detail. 00:27:01.130 --> 00:27:03.710 So the 3 rulings that are listed there at the bottom. 00:27:03.710 --> 00:27:08.300 We're going to touch on each one of those now for different instruments. 00:27:08.300 --> 00:27:12.467 >> 00:26:51.890 --> 00:27:23.660 00:27:12.467 --> 00:27:17.890 >> So the first one in ruling NYN 313219 from July of 2020. 00:27:17.890 --> 00:27:20.544 So we received several different types of devices 00:27:20.545 --> 00:27:22.190 over the last couple of years. 00:27:22.190 --> 00:27:25.250 This particular device contained an infrared thermometer. 00:27:25.250 --> 00:27:27.770 A camera and an 8 inch touchscreen. 00:27:27.770 --> 00:27:29.710 The device also had other secondary features 00:27:29.710 --> 00:27:33.640 such as facial recognition LED lights for obtaining a better visual 00:27:33.640 --> 00:27:39.030 and the user had an RFID reader for scanning badges as well. 00:27:39.030 --> 00:27:41.480 We've also seen different devices that are very similar, 00:27:41.480 --> 00:27:44.067 but also have additional features such as. 00:27:44.067 --> 00:27:44.264 >> 00:27:23.900 --> 00:27:26.370 00:27:44.264 --> 00:27:46.667 >> Opening a door for the user or something along those lines. 00:27:46.667 --> 00:27:52.158 >> 00:27:31.780 --> 00:27:58.920 00:27:52.158 --> 00:27:57.080 >> So when reviewing the device CBP felt that GRI 3 C was the most appropriate 00:27:57.080 --> 00:28:01.750 while 3 C 's not a primary means of classifying I've seen deaf 00:28:01.750 --> 00:28:04.760 several different items containing thermometers over the past few years 00:28:04.760 --> 00:28:07.230 that we found to be an equal consideration 00:28:07.230 --> 00:28:12.030 to another item many times the devices are combined with Chapter 85 items 00:28:12.030 --> 00:28:13.580 and most notably. 00:28:13.580 --> 00:28:18.370 I would say cameras are the one item that seemed to be in close proximity 00:28:18.370 --> 00:28:19.570 with the thermometers. 00:28:19.570 --> 00:28:22.533 >> 00:28:02.290 --> 00:28:06.810 00:28:22.533 --> 00:28:27.200 >> And on the screen here, you just see a the the 3 C 's analysis there. 00:28:27.200 --> 00:28:33.267 >> 00:28:12.820 --> 00:28:32.990 00:28:33.267 --> 00:28:35.610 >> So this slide just runs through some of the logic that we utilized 00:28:35.610 --> 00:28:37.540 to come up with the final classification. 00:28:37.540 --> 00:28:40.570 Note that this ruling was around the same time of Chapter 90 statistical. 00:28:40.570 --> 00:28:42.780 Note 2 ended up coming into play. 00:28:42.780 --> 00:28:45.620 So is the device considered composite good. 00:28:45.620 --> 00:28:46.140 It was found. 00:28:46.140 --> 00:28:50.360 Yes, since there was no primary function or principal function. 00:28:50.360 --> 00:28:53.267 It went to gri 3 C and then. 00:28:53.267 --> 00:28:53.680 >> 00:28:33.770 --> 00:28:48.880 00:28:53.680 --> 00:28:57.680 >> Will end up being last in the tariff was the 1925 a lot 00:28:57.680 --> 00:29:02.570 of times the Chapter 90 merchandise does end up being the deciding factor there 00:29:02.570 --> 00:29:05.860 and then was it considered clinical or nonclinical. 00:29:05.860 --> 00:29:09.133 It was clinical as described by Chapter 90 statistical Note 2. 00:29:09.133 --> 00:29:18.470 >> 00:28:58.160 --> 00:29:09.550 00:29:18.470 --> 00:29:21.170 >> So this screen just shows a shot of the the HTS us 00:29:21.170 --> 00:29:25.510 and the final 9025198010 classification. 00:29:25.510 --> 00:29:27.500 So one thing that I'll point out here is that you'll notice 00:29:27.500 --> 00:29:29.780 on this device provided a temperature reading. 00:29:29.780 --> 00:29:30.733 >> 00:29:10.360 --> 00:29:39.650 00:29:30.733 --> 00:29:33.780 >> If you ended up having a a device that was not only able 00:29:33.780 --> 00:29:37.750 to provide the temperature but also provided that that color images. 00:29:37.750 --> 00:29:41.530 The color image so if you've ever seen like where if something's too hot. 00:29:41.530 --> 00:29:45.220 You kind of like if you were looking at an image of a person 's body 00:29:45.220 --> 00:29:47.990 and certain areas were red that would mean hot 00:29:47.990 --> 00:29:51.110 and if certain areas were cold that would mean cold 00:29:51.110 --> 00:29:53.900 if you can provide those types of thermal images. 00:29:53.900 --> 00:29:56.810 You're getting into more of the items from 902750, which provides 00:29:56.810 --> 00:30:00.133 for the thermal image cameras. 00:30:00.133 --> 00:30:04.267 >> 00:29:41.580 --> 00:29:43.690 >> But in this case, they were just providing. 00:30:04.267 --> 00:30:06.267 >> 00:29:44.340 --> 00:29:45.840 >> The temperature reading. 00:30:06.267 --> 00:30:15.010 >> 00:29:54.700 --> 00:30:14.970 00:30:15.010 --> 00:30:20.360 >> So when ruling New York G 86536 from February of 2001, 00:30:20.360 --> 00:30:22.210 so this is definitely a very interesting ruling 00:30:22.210 --> 00:30:24.660 so the device is a moisture meter. 00:30:24.660 --> 00:30:28.880 That does not contain any batteries so an operation, the the metal probe 00:30:28.880 --> 00:30:32.450 with the zinc head and the copper tube come in contact with the soil 00:30:32.450 --> 00:30:35.480 and when this happens, it creates a voltage that moves the meter. 00:30:35.480 --> 00:30:37.133 >> 00:30:16.650 --> 00:30:19.470 00:30:37.133 --> 00:30:40.000 >> This is kind of an example of uh of the device. 00:30:40.000 --> 00:30:46.281 >> 00:30:25.860 --> 00:30:27.550 00:30:46.281 --> 00:30:47.733 >> So the big question is the. 00:30:47.733 --> 00:30:48.733 >> 00:30:28.270 --> 00:30:32.900 00:30:48.733 --> 00:30:53.221 >> Does this voltage that is created mean that his electrical for HTS us? 00:30:53.221 --> 00:30:54.770 >> 00:30:33.520 --> 00:30:34.170 >> Reasons. 00:30:55.467 --> 00:30:58.170 >> 00:30:35.170 --> 00:30:40.180 >> So just again in the ruling, it states. 00:30:58.170 --> 00:31:00.600 The probe has a zinc head and a copper tube. 00:31:00.600 --> 00:31:01.199 >> 00:30:40.910 --> 00:30:45.340 00:31:01.200 --> 00:31:03.830 >> So inserted into the soil, the The Miller voltage 00:31:03.830 --> 00:31:06.170 of the soil creates 2 different voltages. 00:31:06.170 --> 00:31:08.890 >> 00:30:46.070 --> 00:30:50.520 >> When detecting the 2 different metals. 00:31:08.890 --> 00:31:11.067 This is what moves the actual meter. 00:31:11.067 --> 00:31:18.000 >> 00:30:57.660 --> 00:31:22.090 00:31:18.000 --> 00:31:20.790 >> So, according to Chapter 90 additional US. 00:31:20.790 --> 00:31:25.200 Note 2 electrical references device, which depend on electrical phenomena, 00:31:25.200 --> 00:31:27.800 so again typically this would mean that it's battery operated 00:31:27.800 --> 00:31:30.360 or plugged in however, in this case. 00:31:30.360 --> 00:31:33.270 The electrical phenomenon is performed by the Miller voltage created 00:31:33.270 --> 00:31:35.070 by the meter and the soil. 00:31:35.070 --> 00:31:39.030 This would be considered electrical for tariff purposes. 00:31:39.030 --> 00:31:42.467 So this device ended up going 902580 1000. 00:31:42.467 --> 00:31:51.549 >> 00:31:31.320 --> 00:31:55.200 00:31:51.549 --> 00:31:57.490 >> And now we have headquarters 966940 from July of 2004, 00:31:57.490 --> 00:32:00.170 so this device is also a moisture tester. 00:32:00.170 --> 00:32:02.180 And this except with this one. 00:32:02.180 --> 00:32:06.600 It ends up using calcium carbide gas sealed in the body of the tester 00:32:06.600 --> 00:32:07.540 so an operation. 00:32:07.540 --> 00:32:11.730 The free moisture from the test material reacts with the calcium carbide reagent 00:32:11.730 --> 00:32:15.606 to form an Acetylene gas, which registers the percentage of moisture. 00:32:15.606 --> 00:32:21.994 >> 00:32:01.680 --> 00:32:15.820 00:32:21.994 --> 00:32:25.300 >> So this device is still a hygrometer that determines the moisture level. 00:32:25.300 --> 00:32:28.920 However, the reaction to the gas is how this one operates 00:32:28.920 --> 00:32:31.200 so that is not considered an electrical phenomenon, 00:32:31.200 --> 00:32:36.510 and is therefore classified 9025803500 with the non electrical hydrometers. 00:32:36.510 --> 00:32:37.667 >> 00:32:17.250 --> 00:32:37.440 00:32:37.667 --> 00:32:40.810 >> I hope this helps with like a a real world example 00:32:40.810 --> 00:32:43.310 of the electrical versus non electrical so again. 00:32:43.310 --> 00:32:45.830 Most of what we end up seeing is from the electrical side ends up 00:32:45.870 --> 00:32:49.850 being with the use of batteries or even plugged in. 00:32:49.850 --> 00:32:53.420 But as you'll see from those couple examples. 00:32:53.420 --> 00:32:55.510 There could be other reasons why it would end up you know 00:32:55.510 --> 00:32:57.867 being considered electrical. 00:32:57.867 --> 00:33:05.733 >> 00:32:43.970 --> 00:32:45.530 >> So just a few knowledge checks. 00:33:05.733 --> 00:33:07.190 >> 00:32:46.820 --> 00:33:07.330 00:33:07.190 --> 00:33:11.240 >> So the first one, is where would you classify a plastic shell 00:33:11.240 --> 00:33:13.960 of a clinical forehead thermometer so we provided 00:33:13.960 --> 00:33:20.280 3 different possible locations, including 9033902590 and Chapter 39, 00:33:20.280 --> 00:33:22.520 I'll give everyone just a minute to type in a quick response 00:33:22.520 --> 00:33:25.300 into the chat to see what you guys think between 00:33:25.300 --> 00:33:27.710 where the clinical forehead thermometer would go. 00:33:27.710 --> 00:33:32.782 >> 00:33:12.580 --> 00:33:15.790 00:33:32.782 --> 00:33:36.200 >> I should say the shell of the the forehead thermometer. 00:33:36.200 --> 00:34:17.835 >> 00:33:57.570 --> 00:34:03.860 00:34:17.835 --> 00:34:22.500 >> Alright so I've seen a lot of A 's and B 's 's seem to be leading the way 00:34:22.500 --> 00:34:24.167 as of right now in a few different seas. 00:34:24.167 --> 00:34:29.927 >> 00:34:09.560 --> 00:34:12.760 00:34:29.927 --> 00:34:33.167 >> So remember, according to chapter note. 00:34:33.167 --> 00:34:36.900 >> 00:34:14.110 --> 00:34:16.380 >> So Chapter 90 additional US Note 2. 00:34:36.900 --> 00:34:39.167 >> 00:34:17.920 --> 00:34:18.710 >> It's real quick. 00:34:39.167 --> 00:34:40.200 >> 00:34:44.840 --> 00:35:15.190 00:35:05.190 --> 00:35:10.949 >> And then just going into a couple uh reasons for not being in 9033 or 3926 00:35:10.950 --> 00:35:14.680 to 1933 would only be used if there was not something more specific 00:35:14.680 --> 00:35:16.750 that's already available in this case. 00:35:16.750 --> 00:35:18.310 Chapter 9, the chapter. 00:35:18.310 --> 00:35:22.760 Note 2 B directs us to 9025 and very similar logic ends up putting it 00:35:22.760 --> 00:35:24.460 with the Chapter 39 as well. 00:35:24.460 --> 00:35:29.420 So if if it was just more of a A flat sheet of plastic 00:35:29.420 --> 00:35:32.140 or something like that that hadn't been molded yet now. 00:35:32.140 --> 00:35:36.333 You're talking more of a A Chapter 39 type of product. 00:35:36.333 --> 00:35:36.810 >> 00:35:16.290 --> 00:35:24.470 00:35:36.810 --> 00:35:40.220 >> And again since we do have the the molded shape 00:35:40.220 --> 00:35:44.790 of the thermometer 9025 would be more specific to 9033. 00:35:44.790 --> 00:35:50.800 >> 00:35:30.450 --> 00:35:42.700 00:35:50.800 --> 00:35:54.870 >> Right so this one, the screws below our specifically used to mount 00:35:54.870 --> 00:35:57.880 in front and back casings of the thermometer together 00:35:57.880 --> 00:36:00.980 so the screws are specifically short to handle the the handheld thermometer 00:36:00.980 --> 00:36:02.999 and only measure half an inch long. 00:36:03.000 --> 00:36:05.300 >> 00:35:43.360 --> 00:35:45.110 >> What do you guys think would this be? 00:36:05.300 --> 00:36:06.400 >> 00:35:46.060 --> 00:35:49.190 00:36:06.400 --> 00:36:09.533 >> Classified in 1925 or would these be classified elsewhere. 00:36:09.533 --> 00:36:22.084 >> 00:36:01.810 --> 00:36:31.980 00:36:22.084 --> 00:36:25.570 >> Very good, yeah, everyone seems to be putting chapter 73 00:36:25.570 --> 00:36:29.420 or that they know they wouldn't be 9025 so very good. 00:36:29.420 --> 00:36:33.650 Uh the screws are standard screws and are considered parts of general use 00:36:33.650 --> 00:36:37.370 in classified by constituent material so chapter 90 note. 00:36:37.370 --> 00:36:41.650 One F excludes parts of general use as defined in Note 2 to section XV 00:36:41.650 --> 00:36:47.710 or a base metal or similar goods of plastic so I've seen not only the screws 00:36:47.710 --> 00:36:50.440 of metal, but there's sometimes ends up being the screws 00:36:50.440 --> 00:36:52.400 that are the little plastic screws as well. 00:36:52.400 --> 00:36:52.890 >> 00:36:32.140 --> 00:36:38.110 00:36:52.890 --> 00:36:55.070 >> And the same logic would be applying to those except they would go 00:36:55.070 --> 00:36:58.422 in Chapter 39 as opposed to uh into the medals provision. 00:36:58.422 --> 00:37:06.866 >> 00:36:46.610 --> 00:36:54.100 00:37:06.866 --> 00:37:09.064 >> So now testing one of the key features 00:37:09.065 --> 00:37:11.940 that I was trying to portray today for tariff purposes. 00:37:11.940 --> 00:37:14.520 What are clinical thermometers meant to be used on? 00:37:14.520 --> 00:37:23.567 >> 00:37:03.260 --> 00:37:33.970 00:37:23.567 --> 00:37:25.750 >> Excellent humans and animals very good, 00:37:25.750 --> 00:37:29.340 so the Chapter 90, statistical Note 2, so for the purposes 00:37:29.340 --> 00:37:32.240 of statistical reporting number 9025198010. 00:37:32.240 --> 00:37:36.260 Clinical infrared thermometers are are devices designed to be used 00:37:36.260 --> 00:37:39.750 to check the body temperatures of humans and animals. 00:37:39.750 --> 00:37:44.030 So it's nice that we now have that clarification because I know for 00:37:44.030 --> 00:37:49.750 prior to 2020, there was a lot of debate on exactly what it went into 00:37:49.750 --> 00:37:51.610 and did it have to be for a hospital, setting or or something 00:37:51.610 --> 00:37:53.867 along those lines, but it was. 00:37:53.867 --> 00:37:54.264 >> 00:37:34.100 --> 00:37:37.730 00:37:54.264 --> 00:37:58.200 >> Later clarified in 2020 with the addition of that note so. 00:37:58.200 --> 00:38:00.533 >> 00:37:38.760 --> 00:37:40.210 >> Definitely good to have in there. 00:38:00.533 --> 00:38:05.168 >> 00:37:44.730 --> 00:38:13.270 00:38:05.168 --> 00:38:08.070 >> So I just wanted a very quickly touch on 301 exclusions, 00:38:08.070 --> 00:38:09.120 so as you know 301. 00:38:09.120 --> 00:38:12.730 Section 301 exclusions are definitely never changing item. 00:38:12.730 --> 00:38:14.540 Some of the exclusions of expired and some 00:38:14.540 --> 00:38:17.090 of the other ones have been extended some new exclusions come 00:38:17.090 --> 00:38:19.150 in that are also in effect. 00:38:19.150 --> 00:38:22.110 Just remember that when you're reviewing the Chapter 99 exclusions. 00:38:22.110 --> 00:38:25.590 Please read the exclusion carefully for example, the exclusion 00:38:25.590 --> 00:38:28.365 on the screen will only show apply to cooking thermometers 00:38:28.366 --> 00:38:30.547 and cannot be applied to other thermometers, 00:38:30.547 --> 00:38:33.667 even if they are classified properly in 90251980. 00:38:33.667 --> 00:38:34.867 >> 00:38:14.600 --> 00:38:43.690 00:38:34.867 --> 00:38:38.680 >> Also note that when you're looking at the exclusion. 00:38:38.680 --> 00:38:40.060 You'll end up seeing in the parentheses. 00:38:40.060 --> 00:38:43.070 There so in 2020. 00:38:43.070 --> 00:38:45.660 The exclusions broke out further and expanded 00:38:45.660 --> 00:38:47.820 so now there's a few different possibilities. 00:38:47.820 --> 00:38:50.230 So the way that they ended up doing the 301 exclusions 00:38:50.230 --> 00:38:56.760 for 9025 is they list out the exclusions original classification 00:38:56.760 --> 00:38:59.990 and then they expanded it out to what that classification 00:38:59.990 --> 00:39:01.586 is currently classified so that's why 00:39:01.587 --> 00:39:04.110 you'll end up seeing them written the way that you do there. 00:39:04.110 --> 00:39:10.321 >> 00:38:49.940 --> 00:39:16.930 00:39:10.321 --> 00:39:13.610 >> So I just wanted to let you know, too, 00:39:13.610 --> 00:39:15.480 that the webinars will be posted to this address here. 00:39:15.480 --> 00:39:18.160 So it will be posted for the trade community Umm. 00:39:18.160 --> 00:39:20.579 I'm not sure if these are gonna be posted 00:39:20.580 --> 00:39:22.710 within the next like week to 10 days 00:39:22.710 --> 00:39:25.340 or if these are gonna be ones that they wait until the very end. 00:39:25.340 --> 00:39:27.850 So you can definitely go to the website and take a look. 00:39:27.850 --> 00:39:30.820 I would wait at least a couple weeks before you attempted just to kind of see 00:39:30.820 --> 00:39:33.700 if you know if it has been posted yet. 00:39:33.700 --> 00:39:34.606 But they might be posting it more 00:39:34.607 --> 00:39:37.566 towards the end of the the grouping as well. 00:39:37.566 --> 00:39:41.615 >> 00:39:21.520 --> 00:39:24.030 00:39:41.615 --> 00:39:44.498 >> So I just ended up adding just a few useful links. 00:39:44.499 --> 00:39:45.127 >> 00:39:25.030 --> 00:39:41.320 00:39:45.127 --> 00:39:47.513 >> For those who are not familiar across stands 00:39:47.513 --> 00:39:50.710 for the customs ruling online search system so this is where all 00:39:50.710 --> 00:39:53.430 of the New York and the headquarters rulings are posted. 00:39:53.430 --> 00:39:55.640 It is also a great searchable database. 00:39:55.640 --> 00:39:58.160 They actually make it fairly easy. 00:39:58.160 --> 00:40:01.688 Cpp.gov is also an excellent site for up to date information. 00:40:01.688 --> 00:40:03.133 >> 00:39:42.740 --> 00:40:14.580 00:40:03.133 --> 00:40:05.460 >> And then I know many people end up having their own version 00:40:05.460 --> 00:40:07.250 of the tariff and paper form. 00:40:07.250 --> 00:40:10.190 However, you might want to consider using the link above with the US. 00:40:10.190 --> 00:40:13.310 ITC website when classifying because throughout the year. 00:40:13.310 --> 00:40:15.750 There's definitely several changes that affect the tariff 00:40:15.750 --> 00:40:17.130 and just as an example. 00:40:17.130 --> 00:40:20.660 The major change to 9025 was completed in July of 2020, 00:40:20.660 --> 00:40:24.980 so there was nicely put right in the middle of the the calendar year 00:40:24.980 --> 00:40:26.110 so if you had a printed version. 00:40:26.110 --> 00:40:28.766 You would have not have seen the reflected changes 00:40:28.767 --> 00:40:30.960 when you were classifying and then additionally. 00:40:30.960 --> 00:40:33.380 I just wanted to mention that for the 301 exclusions 00:40:33.380 --> 00:40:34.740 when you're using the online version. 00:40:34.740 --> 00:40:35.134 >> 00:40:14.780 --> 00:40:26.100 00:40:35.134 --> 00:40:38.410 >> The terror of the tariff there's a little blue hyperlink. 00:40:38.410 --> 00:40:43.020 That's next to the number and that would be the link down 00:40:43.020 --> 00:40:47.400 to the the 301 exclusion or the 301. 00:40:47.400 --> 00:40:49.133 >> 00:40:28.790 --> 00:40:32.400 00:40:49.133 --> 00:40:53.267 >> The 301 that's applicable to that particular HTS number. 00:40:53.267 --> 00:40:55.540 >> 00:40:33.310 --> 00:41:01.120 >> So when you click on the the link. 00:40:55.540 --> 00:40:58.950 It automatically brings you down to the corresponding 301 number 00:40:58.950 --> 00:41:02.560 and you definitely won't get that level of service from your paper version 00:41:02.560 --> 00:41:03.410 and just know too. 00:41:03.410 --> 00:41:08.380 That if you ended up opening up Uh Chapter 99, then you could do a search 00:41:08.380 --> 00:41:13.090 by the actual HTS number and then that'll also bring up a bunch 00:41:13.090 --> 00:41:14.910 of the exclusions that are out there, so if you were doing. 00:41:14.910 --> 00:41:16.410 The research to it. 00:41:16.410 --> 00:41:19.090 The online version is definitely the easier version to go through 00:41:19.090 --> 00:41:21.467 as opposed to everything else that's out there. 00:41:21.467 --> 00:41:23.467 >> 00:41:03.070 --> 00:41:33.350 00:41:23.467 --> 00:41:26.430 >> And then just a few classification tools again. 00:41:26.430 --> 00:41:29.380 Cross isn't the end all, be all, so definitely look 00:41:29.380 --> 00:41:33.350 at your dris your additional rules of interpretation your section chapter 00:41:33.350 --> 00:41:34.470 and heading notes. 00:41:34.470 --> 00:41:38.240 I know we went over the some of the explanatory notes and the notes 00:41:38.240 --> 00:41:41.270 that were earlier on when it comes to 9025. 00:41:41.270 --> 00:41:47.160 So also be a as cognizant as you can as the the relevant court cases 00:41:47.160 --> 00:41:48.560 and the precedent rulings. 00:41:48.560 --> 00:41:51.930 I know court cases are a little bit more difficult to find and locate 00:41:51.930 --> 00:41:53.667 but just know that. 00:41:53.667 --> 00:41:53.790 >> 00:41:33.470 --> 00:41:41.380 00:41:53.790 --> 00:41:56.310 >> When you're doing all of your classifications. 00:41:56.310 --> 00:42:00.440 Sometimes the court cases can definitely change the outcome 00:42:00.440 --> 00:42:01.880 of certain classifications. 00:42:01.880 --> 00:42:06.400 >> 00:41:46.140 --> 00:41:55.000 00:42:06.400 --> 00:42:09.800 >> So this is the end of my presentation. 00:42:09.800 --> 00:42:12.620 I will go back and try to see if I can see any of the questions 00:42:12.620 --> 00:42:13.920 that you may have already asked. 00:42:13.920 --> 00:42:15.667 I don't know if some of them got answered. 00:42:16.269 --> 00:42:17.532 >> 00:41:57.090 --> 00:42:31.180 00:42:17.533 --> 00:42:20.810 >> The most important part of this slide just know that you can contact me. 00:42:20.810 --> 00:42:22.360 I have my phone number here. 00:42:22.360 --> 00:42:26.530 The email address is typically the easiest way to get a hold of me. 00:42:26.530 --> 00:42:30.820 So when you're going through feel free either to ask a question now 00:42:30.820 --> 00:42:33.090 or after the fact I've when we've done. 00:42:33.090 --> 00:42:34.840 These presentations in the past. 00:42:34.840 --> 00:42:39.880 We definitely get a good amount of questions that come in after the fact 00:42:39.880 --> 00:42:43.130 so I just want to make sure that that you do have my email address, 00:42:43.130 --> 00:42:45.370 so that you can ask something after the fact as well, 00:42:45.370 --> 00:42:48.700 sometimes when it's product specific. 00:42:48.700 --> 00:42:51.670 We don't want to get too far into it without having a binding ruling. 00:42:51.670 --> 00:42:51.891 >> 00:42:31.370 --> 00:42:45.900 00:42:51.891 --> 00:42:53.533 >> So it could come down to me. 00:42:53.533 --> 00:42:55.390 Just saying, You know if it gets too. 00:42:55.390 --> 00:42:59.540 Detailed just submit for binding ruling or if it needs a little bit more. 00:42:59.540 --> 00:43:02.110 Uh you know answers to any other questions. 00:43:02.110 --> 00:43:05.067 Prior to a binding ruling being put in I answer a lot of those questions 00:43:05.067 --> 00:43:06.133 as well so. 00:43:06.133 --> 00:43:07.232 >> 00:42:46.870 --> 00:42:49.540 00:43:07.232 --> 00:43:10.200 >> So I will go back and kind of take a look if I can. 00:43:10.200 --> 00:43:13.800 >> 00:42:53.490 --> 00:42:58.920 00:43:13.800 --> 00:43:17.670 >> With thermometers used in aquariums, and terrariums be considered clinical 00:43:17.670 --> 00:43:19.333 or other in general. 00:43:19.333 --> 00:43:22.533 >> 00:43:00.030 --> 00:43:01.600 >> That is a good question. 00:43:22.533 --> 00:43:24.133 >> 00:43:03.830 --> 00:43:12.800 00:43:24.133 --> 00:43:29.330 >> To me that seems like it's more, the temperature of the water, 00:43:29.330 --> 00:43:33.933 not the temperature of the actual fish so. 00:43:33.933 --> 00:43:34.500 >> 00:43:13.550 --> 00:43:23.630 00:43:34.500 --> 00:43:36.170 >> I would probably lean towards it not being clinical, 00:43:36.170 --> 00:43:38.300 but that would be one that's definitely close. 00:43:38.300 --> 00:43:40.940 And I would probably end up going through and double checking and 00:43:40.940 --> 00:43:43.931 and I'd wanna research that one a little bit more. 00:43:43.931 --> 00:43:52.876 >> 00:43:32.400 --> 00:43:37.420 00:43:52.876 --> 00:43:56.362 >> Scrolling up to see if there's any additional questions 00:43:56.363 --> 00:43:57.721 that I might be able to answer. 00:43:57.721 --> 00:44:02.733 >> 00:43:41.430 --> 00:43:44.900 >> Or if you do have any questions. 00:44:02.733 --> 00:44:05.333 Feel free to put it into the chat box now. 00:44:05.333 --> 00:44:24.421 >> 00:44:04.060 --> 00:44:12.680 00:44:24.421 --> 00:44:27.230 >> So for recording instruments does the apparatus itself need 00:44:27.230 --> 00:44:32.867 to carry out the recording function to be in 902580 or can the apparatus? 00:44:32.867 --> 00:44:36.933 >> 00:44:16.670 --> 00:44:46.840 00:44:36.933 --> 00:44:40.140 >> Produce, a signal output like a computer signal to separate 00:44:40.140 --> 00:44:41.630 to a separate device. 00:44:41.630 --> 00:44:44.590 Typically, what I end up seeing is with the recording ones 00:44:44.590 --> 00:44:50.180 is they're all contained in the same instrument so typically what I've done. 00:44:50.180 --> 00:44:53.440 You know it has to be able to do everything all in one, 00:44:53.440 --> 00:44:54.770 so to a separate computer. 00:44:54.770 --> 00:44:58.220 A lot of times that would be more like a a temperature sensor 00:44:58.220 --> 00:45:01.690 is probably the one that I see most so a temperature sensor 00:45:01.690 --> 00:45:06.140 might plug into an Ethernet cable as well, and then send something 00:45:06.140 --> 00:45:06.970 to a computer that. 00:45:06.970 --> 00:45:07.357 >> 00:44:46.970 --> 00:44:56.590 00:45:07.357 --> 00:45:10.520 >> Gathers not only the temperature data, but maybe humidity data 00:45:10.520 --> 00:45:11.840 and other things as well. 00:45:11.840 --> 00:45:12.560 In those cases. 00:45:12.560 --> 00:45:16.799 Typically, it might be more of a an electronic means as opposed to. 00:45:16.799 --> 00:45:20.067 >> 00:44:57.460 --> 00:44:59.550 >> At being a recording apparatus. 00:45:20.067 --> 00:45:30.911 >> 00:45:10.540 --> 00:45:16.340 00:45:30.911 --> 00:45:32.850 >> A lot of the other questions are just are we recording 00:45:32.850 --> 00:45:34.750 and a few other speaker issues. 00:45:34.750 --> 00:45:36.728 So it seems like those have kind of been answered. 00:45:36.728 --> 00:45:37.990 >> 00:45:17.560 --> 00:45:20.270 00:45:37.990 --> 00:45:39.860 >> Try to scroll back down to see if there's anything new. 00:45:39.883 --> 00:45:41.253 >> 00:45:32.390 --> 00:45:36.430 00:45:52.833 --> 00:45:54.919 >> For the recording instruments as the apparatus itself need 00:45:54.920 --> 00:45:55.510 to carry out so OK. 00:45:55.510 --> 00:45:57.200 I just answered that one. 00:45:57.200 --> 00:45:59.200 >> 00:45:38.890 --> 00:45:42.730 00:45:59.200 --> 00:46:01.570 >> A temperature management system where the machine heats 00:46:01.570 --> 00:46:03.133 or cools a patient. 00:46:03.133 --> 00:46:04.133 >> 00:45:43.830 --> 00:46:17.540 00:46:04.133 --> 00:46:07.733 >> That one we would definitely need to look further into 00:46:07.733 --> 00:46:10.760 because there's a lot of there's a lot of moving parts there, 00:46:10.760 --> 00:46:13.540 so a lot of times when it comes to 9025. 00:46:13.540 --> 00:46:15.960 Especially when it comes to temperatures. 00:46:15.960 --> 00:46:22.830 It's more just the temperature reading aspect as opposed to just as an example. 00:46:22.830 --> 00:46:27.930 Some of like the thermostats are in 9032, where they're control devices. 00:46:27.930 --> 00:46:31.740 So those devices might also not only get the temperature 00:46:31.740 --> 00:46:34.750 but then they're trying to make that temperature stay 00:46:34.750 --> 00:46:37.550 within a certain parameter setting so that you can actually have. 00:46:37.550 --> 00:46:38.107 >> 00:46:17.780 --> 00:46:30.070 00:46:38.107 --> 00:46:41.720 >> You know in this case, a patient might be at a certain temperature. 00:46:41.720 --> 00:46:45.210 Maybe they have to be cooled down to 94 degrees or you know, 00:46:45.210 --> 00:46:46.219 or or even less or whatever. 00:46:46.219 --> 00:46:50.467 The case may be that might be something that would be beyond 9025. 00:46:50.467 --> 00:46:52.733 >> 00:46:32.240 --> 00:46:36.850 00:46:52.733 --> 00:46:54.960 >> But if you want to send me an email, I could definitely look 00:46:54.960 --> 00:46:56.980 into that a little bit further just to see exactly what you have. 00:46:56.980 --> 00:47:05.200 >> 00:46:44.840 --> 00:46:52.320 00:47:05.200 --> 00:47:09.730 >> So Matt ended up asking why does 9025198085 have a 301 exclusion 00:47:09.730 --> 00:47:12.530 for COVID when clinical thermometers would not be classified there? 00:47:12.530 --> 00:47:13.933 >> 00:46:53.570 --> 00:47:21.760 00:47:13.933 --> 00:47:18.370 >> As you probably know the the the 301 exclusions are definitely not perfect. 00:47:18.370 --> 00:47:21.610 So we've definitely had a lot of the 3 oh ones exclusions 00:47:21.610 --> 00:47:25.240 that got submitted around you know in a very short time and 00:47:25.240 --> 00:47:26.600 and tight turn around time. 00:47:26.600 --> 00:47:28.940 So we ended up doing a lot of reviews during that time, but there 00:47:28.940 --> 00:47:32.110 might be a couple out there that maybe were an error 00:47:32.110 --> 00:47:36.040 or didn't get worded exactly as intended. 00:47:36.040 --> 00:47:38.850 Or you know a lot of times the the exclusions, 00:47:38.850 --> 00:47:41.800 especially for the thermometers there was not only. 00:47:41.800 --> 00:47:44.130 >> 00:47:23.720 --> 00:47:31.450 00:47:44.130 --> 00:47:45.907 >> There was not only like the thermometers 00:47:45.923 --> 00:47:47.199 that were for the The Clinical. 00:47:47.200 --> 00:47:50.320 But everything kind of got bumped in or you know, whatever the case may be so. 00:47:50.320 --> 00:47:52.070 >> 00:47:32.240 --> 00:47:41.960 00:47:52.070 --> 00:47:56.030 >> I don't have a great answer for why it might not be classified 00:47:56.030 --> 00:48:02.333 in that particular heading but I know that as of 2020 the? 00:48:02.333 --> 00:48:02.640 >> 00:47:42.690 --> 00:47:47.360 00:48:02.640 --> 00:48:07.085 >> The clinical versus Nonclinical ended up being more differentiated 00:48:07.086 --> 00:48:07.999 at that point. 00:48:08.000 --> 00:48:08.732 >> 00:47:48.390 --> 00:47:51.470 00:48:08.733 --> 00:48:10.210 >> So some of those exclusions might have come out 00:48:10.210 --> 00:48:10.640 prior to that as well. 00:48:10.640 --> 00:48:16.000 >> 00:47:55.750 --> 00:48:10.500 00:48:16.000 --> 00:48:19.190 >> So will you be doing a session on 90 20:07 in the future 00:48:19.190 --> 00:48:20.550 that's definitely a possibility. 00:48:20.550 --> 00:48:23.930 I mean, if there's definitely uh 9027 definitely has 00:48:23.930 --> 00:48:25.560 a lot more complicated machinery. 00:48:25.560 --> 00:48:29.730 That's that's part of it, but 9027 can definitely be something in the future 00:48:29.730 --> 00:48:31.480 that we, we discuss. 00:48:31.480 --> 00:48:42.533 >> 00:48:22.310 --> 00:48:23.520 00:48:42.533 --> 00:48:44.250 >> Rolling through again. 00:48:44.250 --> 00:48:49.058 >> 00:48:28.770 --> 00:48:30.350 00:48:49.058 --> 00:48:51.280 >> That like 12. 00:48:51.280 --> 00:48:53.800 >> 00:48:31.840 --> 00:48:33.390 >> Someone just asked to see 12 again. 00:48:53.800 --> 00:49:01.628 >> 00:48:41.360 --> 00:48:44.050 00:49:01.628 --> 00:49:04.367 >> So slide 12 was just the an overview slide there. 00:49:04.367 --> 00:49:12.678 >> 00:48:52.300 --> 00:49:12.200 00:49:12.678 --> 00:49:14.800 >> I'm not seeing any additional questions 00:49:14.800 --> 00:49:17.030 so if there's no additional questions again. 00:49:17.030 --> 00:49:20.800 Feel free to reach out to myself or or John when he does come back. 00:49:20.800 --> 00:49:24.690 He'll be back in a couple months from schooling and I will hopefully be able 00:49:24.690 --> 00:49:28.040 to answer any additional questions that you have and again just keep in mind. 00:49:28.040 --> 00:49:29.207 The binding rulings as well 00:49:29.207 --> 00:49:32.667 so that'll help solidify some of the classifications that you might have. 00:49:32.667 --> 00:49:34.467 >> 00:49:14.140 --> 00:49:17.950 All right well. 00:49:34.467 --> 00:49:37.960 Thank you very much and I appreciate everyone's attention. 00:49:37.960 --> 00:49:38.960 Thank you.