CAAR Ruling: Alexa Voice Remote (3rd Gen) Classified as Radio Control Apparatus

The Customs Authority for Advance Rulings (CAAR) classified the Alexa voice remote (3rd Gen) under Custom Tariff Item (CTI) 8526 92 00 as a radio remote control apparatus, rather than the proposed CTI 8517 62 90. Consequently, the device does not qualify for duty exemption under Serial No. 20 of Notification No. 57/2017-Customs, which applies to goods under sub-heading 8517 62 90.

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Issues Involved:
1. Classification of Alexa voice remote (3rd Gen) under the Customs Tariff.
2. Eligibility for duty exemption under Serial No. 20 of Notification No. 57/2017-Customs dated 30.06.2017.

Issue-wise Detailed Analysis:

1. Classification of Alexa Voice Remote (3rd Gen) under the Customs Tariff:
The applicant, M/s Amazon Wholesale India Private Limited, sought an advance ruling on the classification of the Alexa voice remote (3rd Gen) under the Customs Tariff Act, 1975. The applicant proposed classification under Custom Tariff Item (CTI) 8517 62 90, which covers apparatus for the transmission or reception of voice, image, or other data, including communication apparatus in a wired or wireless network.

The Principal Commissioner of Customs, ACC (Import), New Delhi, concurred with the applicant's proposed classification under CTI 8517 62 90. However, the Customs Authority for Advance Rulings (CAAR) considered an alternative classification under CTI 8526 92 00, which covers radio remote control apparatus.

The CAAR analyzed the device's functionality, noting that it operates primarily as a remote control for the Fire TV Stick, using Bluetooth technology to transmit and receive commands. Despite the applicant's argument that Bluetooth technology differentiates the device from radio remote control apparatus, the CAAR found that Bluetooth operates using ultra-high frequency (UHF) radio waves. Therefore, the principal function of the Alexa voice remote (3rd Gen) aligns with radio remote control apparatus.

The CAAR referenced the Harmonized System Nomenclature (HSN) guidelines and Canada's Border Service Agency's memorandum, concluding that the principal function of the Alexa voice remote (3rd Gen) is to act as a radio remote control apparatus. Thus, the appropriate classification is under CTI 8526 92 00.

2. Eligibility for Duty Exemption under Serial No. 20 of Notification No. 57/2017-Customs:
The second issue addressed whether the Alexa voice remote (3rd Gen) qualifies for duty exemption under Serial No. 20 of Notification No. 57/2017-Customs, dated 30.06.2017. This notification provides duty exemptions for goods falling under sub-heading 8517 62 90, excluding wrist wearable devices (smartwatches).

Since the CAAR determined that the Alexa voice remote (3rd Gen) is classifiable under sub-heading 8526 92 00, it does not qualify for the duty exemption specified under Serial No. 20 of Notification No. 57/2017-Customs. The exemption is only applicable to goods classified under sub-heading 8517 62 90, which does not include the Alexa voice remote (3rd Gen).

Conclusion:
The CAAR ruled that the Alexa voice remote (3rd Gen) is classifiable under CTI 8526 92 00 as a radio remote control apparatus. Consequently, it does not qualify for the duty exemption under Serial No. 20 of Notification No. 57/2017-Customs, which is limited to goods under sub-heading 8517 62 90.

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