Mobileye 8 Connect Classified as Sound Signalling Equipment Under Customs Tariff Heading 8512 30 90.

Mobileye 8 Connect is classified under Customs Tariff Heading 8512 30 90 as "Sound signalling equipment" according to the Customs Tariff Act, 1975. The Authority determined that its primary function is to alert drivers, not to perform surveying or mapping, aligning it with Chapter Heading 8512. The applicant's arguments for classification under Chapter 87 and Chapter 90 were rejected, as the device's functionalities did not fit the criteria for surveying instruments or motor vehicle parts and accessories.

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Issues Involved:
1. Classification of Mobileye 8 Connect under the Customs Tariff Act, 1975.

Summary:

Issue 1: Classification under Chapter 85 of the Customs Tariff

The applicant considered Chapter Heading 8512, which covers "Electrical lighting or signalling equipment... of a kind used for cycles or motor vehicles." The applicant argued that the principal function of Mobileye Connect is not signalling but surveying, mapping, and plotting, thus ruling out classification under heading 8512.

Issue 2: Classification under Chapter 87 of the Customs Tariff

The applicant examined Heading 8708, which pertains to "Parts and accessories of motor vehicles of headings 8701 to 8705." They argued that surveying instruments are not mentioned or covered under this heading and are specifically excluded by Note 2(f) and Note 2(g) of Section XVII, which exclude articles of Chapter 85 and Chapter 90. Therefore, Mobileye Connect cannot be classified under Heading 8708.

Issue 3: Classification under Chapter 90 of the Customs Tariff

The applicant argued for classification under Heading 9015, which covers "Surveying (including Photogrammetrical surveying)... instruments and appliances." They claimed that Mobileye Connect functions similarly to a Photogrammetrical Surveying Instrument, taking digital images and processing them to alert drivers. They cited various legal precedents and advanced rulings from other jurisdictions to support their claim.

Authority's Analysis and Decision:

The Authority examined the applicant's submissions, including rulings from German and US Customs authorities and various case laws. The Authority found that the German rulings pertained to different types of mapping systems that are not similar to Mobileye Connect. The US rulings were for specific sensor modules classified under HTSUS 9015, which also did not align with Mobileye Connect's functionality.

The Authority noted that Mobileye 8 Connect is marketed as an "Advance Driver Assistance System" (ADAS) and provides five types of alerts to drivers, including Forward Collision Warnings, Headway Monitoring Warning, Lane Departure Warning, Pedestrians and Cyclist Warning, and Speed Limit Indicator. The primary function of Mobileye 8 Connect is to alert the driver, not to perform surveying or mapping.

The Authority concluded that the principal function of Mobileye 8 Connect is to operate as an alert system for drivers, which falls under Chapter Heading 8512, specifically under tariff entry 8512 30 90: "Sound signalling equipment."

Ruling:

Mobileye 8 Connect is classified under Customs Tariff Heading 8512 30 90: "Sound signalling equipment" of the Customs Tariff Act, 1975.

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