Echo Smart Displays Are Transmission Devices, CBP HQ Rules
Amazon's Echo Show smart displays are properly classified as "machines for the reception, conversion and transmission or regeneration of voice, images or other data" under subheading 8517.62.00, rather than as speakers of heading 8518, CBP said in a recently released ruling. In HQ H316742, dated June 3 and released Aug. 30, CBP found heading 8517 better described the principal function of the multifunction Alexa devices.
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CBP found that the Echo Show 5, 8 and 10 were multifunction composite machines, capable of performing a variety of tasks and composed of parts that are themselves machines classifiable under various subheadings. The components perform "separate but complementary functions," CBP said.
The integrated chips and processors receive and process commands from a user, and then transmit the resulting data requests through a user’s connected Wi-Fi router to servers. The external servers interpret the transmitted requests and send the appropriate data signals back to the devices, where they are processed by the integrated chips and processors to accomplish a task. Internal circuitry converts data into electrical current that is conveyed to the integrated speakers. The speakers produce sound by converting that electric current into sound waves. The integrated microphone array receives audible commands from users. The touchscreen enables visual and tactile interaction. The camera records videos and images.
According to Note 3 of Section XVI, multifunction and composite machines are to be classified as if they consist "only of the component which performs the principal function." In its analysis, CBP ruled that the Echo Shows were "essentially remote access devices" that allowed users to send and receive data from external servers over wireless networks to accomplish various tasks and to control other devices remotely. Although the devices contained speakers integral to user interaction and heading 8518 provides for speakers designed for connection to an automatic data processing machine, CBP found that the ability to transmit sound was not the primary function of the devices.
Instead, CBP found that the devices' principal function was the coordination of data between services and other networked devices. The function is most notable in the device's "broad ability and design to serve as an interface between users and the various applications residing on external servers," CBP said. This reception and transmission of data as a principal functionality is best described under heading 8517 as "Other apparatus for the transmission or reception of voice, images, or other data … including apparatus for communication in a wired or wireless network ...” and more specifically as "Machines for the reception, conversion and transmission or regeneration of voice, images or other data, including switching and routing apparatus,” provided for in subheading 8517.62.00.