Wireless communication modules and development boards were classified under heading 8517, not as data-processing machines or parts thereof.

Classification of an embedded development board and wireless module was determined under the General Rules for Interpretation, Chapter Notes and HSN guidance by reference to their essential character and principal function. The ESP32-C3-DevKitM-I-N4X development board was treated as a programmable embedded platform whose dominant feature was integrated Wi Fi and Bluetooth communication, so it was not classified as an automatic data processing machine or unit under heading 8471 and was placed under heading 8517. The ESP32-C3-WROOM-02-N4 module was likewise found to be an independent wireless communication module with integrated processing and transceiver functions, not a part or accessory under heading 8473, and was also classified under heading 8517.

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Issues: (i) Whether the Espressif ESP32-C3-DevKitM-I-N4X Development Board is classifiable under tariff heading 8471 as an automatic data processing machine or unit thereof, or under tariff heading 8517 as other apparatus for the transmission or reception of data in a wireless network; (ii) Whether the Espressif ESP32-C3-WROOM-02-N4 Module is classifiable under tariff heading 8473 as a part or accessory of an automatic data processing machine, or under tariff heading 8517 as other apparatus for the transmission or reception of data in a wireless network.

Issue (i): Whether the Espressif ESP32-C3-DevKitM-I-N4X Development Board is classifiable under tariff heading 8471 as an automatic data processing machine or unit thereof, or under tariff heading 8517 as other apparatus for the transmission or reception of data in a wireless network.

Analysis: Classification was determined on the basis of the General Rules for Interpretation, Chapter Notes to Chapter 84, and the HSN guidance. The development board was found to be a programmable embedded platform, but its essential character was derived from its integrated Wi-Fi and Bluetooth communication capability rather than from general-purpose data processing. It was held not to satisfy the requirements of an automatic data processing machine or a unit thereof, and not to fall within heading 8471.

Conclusion: The board was held classifiable under tariff heading 8517, more specifically under sub-heading 8517 62 90.

Issue (ii): Whether the Espressif ESP32-C3-WROOM-02-N4 Module is classifiable under tariff heading 8473 as a part or accessory of an automatic data processing machine, or under tariff heading 8517 as other apparatus for the transmission or reception of data in a wireless network.

Analysis: The module was found to be an independent wireless communication module with integrated processing and transceiver functions. It was not held to be a part solely or principally used with machines of heading 8471, and heading 8473 was therefore found inapplicable. Its principal function was identified as wireless transmission and reception of data.

Conclusion: The module was held classifiable under tariff heading 8517, more specifically under sub-heading 8517 62 90.

Final Conclusion: The requested classifications under headings 8471 and 8473 were not accepted, and both products were held to fall under heading 8517 as other wireless communication apparatus.

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