TaxTMI 
TaxTMI 
2026 (7) TMI 22
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...., Uran and Air Cargo Complex, Mumbai. 2. Applicant's Submissions: 2.1: The applicant is presently operating the e-commerce platform Robu.in, selling a wide range of electronic components, robotic parts, and DIY kits. The company also offers services like 3D printing, prototyping, and assembly. The applicant intends to import two items, i.e., "Espressif ESP32-C3- DevKitM-I-N4X Development Board (Microcontroller Development Board)" and "SOC Product -Espressif ESP32-C3-WROOM-02-N4 Module". As per the present scheme of Classification of Commodities under the Customs Tariff Act, of 1975, "Espressif ESP32-C3-DevKitM-1 -N4X Development Board (Microcontroller Development Board)" is correctly classifiable under Customs Tariff Item 84719000, and "SOC Product -- Espressif ESP32-C3-WROOM-02-N4 IWodule" is correctly classifiable under Customs Tariff Item 84733010. 2.2 The following is the question for which an advance ruling. has been sought by the Applicant: Whether the "Espressif ESP32-C3-DevKitM-I-N4X Development Board (Microcontroller Development Board)" proposed to be imported will be classified under the Customs Tariff Item (CTI) 84719000 of the Customs Tariff Act of....
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....edical devices, remote controls, office machines, appliances, power tools, toys, and other embedded systems. By reducing the size and cost compared to a design that uses a separate microprocessor, memory, and input/output devices, microcontrollers make digital control of more devices and processes practical. Mixed- signal microcontrollers are common, integrating analog components needed to control non- digital electronic systems. In the context of the Internet of Things, microcontrollers are an economical and popular means of data collection, sensing, and actuating the physical world as edge devices. * Embedded design : A microcontroller can be considered a self-contained system with a processor, memory and peripherals and can be used as an embedded system. The majority of microcontrollers in use today are embedded in other machinery, such as automobiles, telephones, appliances, and peripherals for computer systems. While some embedded systems are very sophisticated, many have minimal requirements for memory and program length, with no operating system, and low software complexity. Typical input and output devices include switches, relays, solenoids, LEDs, small o....
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....rocessing speed, programmable nature, and multitasking capability) and a microcontroller (due to onboard memory, I/O control and peripheral interfaces). * Key applications: * Io'T and smart devices: Its Wi-Fi and Bluetooth capabilities make it ideal for connecting devices to the internet or to each other for home automation, cloud-based security, and other smart projects. * Educational and Learning Projects: it is widely used in schools, colleges and technical training programs for teaching embedded systems, programming, and IoT concepts. * Audio and voice applications: With its dual-core processor and other integrated components, it can handle demanding tasks such as voice encoding and MP3 decoding. * Prototyping and hobbyist projects: it is a popular choice for beginners and developers to build and prototype new devices and applications. * Industrial and low-power applications: Its reliability in a wide temperature range and ability to operate in low-power modes make it suitable for industrial environments and battery- operated devices. Conclusion: The ESP 32 module is a compact, versatile, and low-cost, ....
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....cooling system on or off. * Data Transmission: With built-in Wi-Fi and Bluetooth capabilities, the ESP32 can automatically send processed data to cloud services, a smartphone app (like Blynk or Firebase), or other connected devices for remote monitoring and analysis. This is a core function in loT applications. In essence, the ESP32 is a dedicated, programmable machine that processes data automatically based on its programming and inputs, fulfilling the definition of an automatic data processing machine in the context of embedded systems and IoT. (ii) The ESP32-C3-DevKitM-1-N4X isn't only for communication; it's a versatile microcontroller board for IoT (Internet of Things) projects, combining wireless (Wi- FI / Bluetooth) communication with processing power (RISC-V CPU) to control devices, read sensors, and connect to the internet for smart home, wearables, and industrial automation, acting as the brain for connected "machines" or devices. The Espressif ESP32-C3-DevKitM-I-N4X is excellent for robotics (often called 'Roboptics' in some contexts), especially for DIY/hobbyist projects, as it's a budget-friendly microcontroller b....
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....ODED FORM AND MACHINES FOR PROCESSING SUCH DATA, NOT ELSEWHERE SPECIFIED OR INCLUDED 8471 30 - Portable digital automatic data processing machines, weighing not more than 10 kg, consisting of at least a central processing unit, a keyboard and a display: 8471 30 10 --- Personal computer u Free - 8471 30 90 --- Other u Free - - Other automatic data processing machines : 8471 41 -- Comprising in the same housing at least a central processing unit and an input and output unit, whether or not combined : 8471 41 10 --- Micro computer u Free - 8471 41 20 --- Large or main frame computer u Free - 8471 41 90 --- Other u Free - 8471 49 00 -- Other, presented in the form of systems u Free - 8471 50 00 - Processing units other than those of sub-headings 8471 41 or 8471 49, whether or not containing in the same housing one or two of the following types of unit: storage units, input units, output units u....
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....- Automatic data processing machines may be in the form of systems consisting of a variable number of separate units. Subject to paragraph (E) below, a unit is to be regarded as being a part of a complete system if it meets 'all of the following conditions; (a) it is of a kind solely or principally used in an automatic data processing system; (b) it 'is connectable to the central processing unit either directly or through one or more other units; and (c) it is able to accept or deliver data in a form (codes or signals) which can be used by the system. Note 5 - (C) Separately presented units of an automatic data processing machine are to be classified in heading 84.71. Note 5 - (D) Printers, Keyboards, X-Y co-ordinate input devices, and disk storage units which satisfy the conditions of paragraphs (B) (b) and (B) (c) above, are in all cases to be classified as units of heading 84.71. Note 5 - (E) Machines performing a specific function other than data processing and incorporating er working in conjunction with an automatic data processing machine are to be classified in the headings appropriate to their respective functions or, f....
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....and clarification, the subject goods are specifically covered under the heading 8471 - Automatic data processing machines and units thereof. The specific heading prevails over the general heading. The subject goods are not covered under 847130, 847141, 847149, & 847150 because it does not contain housing, any input or output devices. The most appropriate heading is 84719000. 9. Furthermore, the Specific Heading will prevail over the General Heading: (i) it is a trite law that whenever there is a specific entry, the same would prevail over a general entry. The said general principle is statutorily incorporated in the General Rules of Interpretation, in particular, under Rule 3(a) of the General Rules of Interpretation, which reads as under: "Rule 3. When by application of Rule 2(b) or for any other reason, goods are, prima facie, classifiable under two or more headings, classification shall be effected as follows: (a) The heading which provides the most specific description shall be preferred to headings providing a more general description. However, when two or more headings each refer to part only of the materials or substances contained in m....
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....her, in the subject goods, the active and passive elements are fixed on a printed circuit board. Therefore, the subject goods are excluded from CTH 8542, and it is correctly covered under CTH 8471. 11. The applicant stated that, the subject goods cannot be classified as part of any machine because, in the form it is imported cannot be used as assemblies in the heading appropriate to the machine or appliance. Further, the subject goods do not satisfy the functions laid down in Note 5(E) of Chapter 84. It is not a machine performing a specific function but a freely programmable board/machine. After clearance of the goods for home consumption, it is a post- import activity to program the development board with the application Software before using it for any specific purpose, or with a particular type of machine in a particular industry, or for general education/domestic use. Therefore, the form that the subject goods will be imported will be only a data processing machine without any housing or any input/output devices. It is considered a freely programmable, entry-level development board featuring the ESP32-C3 chip with integrated Wi-Fi and Bluetooth LE, offering accessible GPIOs....
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.... with up to 4MIB Flash memory and a PCB antenna, ideal for cost-effective smart devices needing wireless connectivity and security features like secure boot and flash encryption, as detailed on Espressif s product pages and developer resources. The Espressif ESP32-C3-WROOM-02-N4 is built around an ESP32- C3 microcontroller System on a Chip (SoC), making it a powerful, integrated solution for IoT with a RISC-V core, Wi-FI, Bluetooth, and peripherals, not just a simple microprocessor but a full microcontroller SoC. Key Components & Features: * Core: A 32-bit RISC-V single-core processor, running up to 160 MHZ. * Connectivity: Integrated 2.4GHz Wi-FI (802.11 b/g/n) and Bluetooth 5 LE (Low Energy). * Memory: Includes 4MB external SPI Flash (the 'N4' in the name), 400KB SRAM, and 384KB ROM on the chip. * Peripherals: Rich set of GPIOs, ADC, UART, SPI, 12C, PWM, and a USB Serial/JTAG controller for programming/debugging. * Module Design: Comes as a compact module with an integrated PCB antenna for casy integration into devices. 13.2 Photo of "SOC Product -Espressif ESP32-C3-WROOM-02-N4 Module" found on the Website is as bel....
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....ipally with machines of heading. 8470 to 8472 are covered under heading 8473. Therefore, the "SOC Product -Espressif ESP32-C3-WRC)OM-02-N4 Module", being a microprocessor and a part of the data processing machine, is correctly, properly, and specifically covered under 84733010. 13.5 The Specific Heading will prevail over the General Heading: (i) it is a trite law that whenever there is a specific entry, the same would prevail over a general entry. The said general principle is statutorily incorporated in the General Rules of Interpretation, in particular, under Rule 3(a) of the General Rules of Interpretation, which reads as under: "Rule 3. When by application of Rule 2(b) or for any other reason, goods are, prima facie, classifiable under two or more headings, classification shall be effected as follows : (a) The heading which provides the most specific description shall be preferred to headings providing a more general description. However, when two or more headings each refer to part only of the materials or substances contained in mixed or composite goods or to part only of the items in a set put up for retail sale, those headings are to be regarde....
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....esigners can choose modules with or without wireless features depending on application needs. (b) The applicant has also submitted a separate Technical Clarification/ Literature of Independent & Primary Microcontroller / Microprocessor Functionality. Regarding the products :. * ESP32-C3-DevKitM-1-H4X * ESP32-C3-WROOM-02-N4 As per the applicant, the CPU/microprocessor in all ESP32 modules is the primary function and operates independently, performing data processing, control, and peripheral management without requiring any wireless hardware support. Wi-Fi and Bluetooth are secondary functions, available in certain series or module variants, and can be enabled, disabled, or omitted entirely depending on application requirements. From the technical clarifications/literatures, submitted by the manufacturer supplier and the applicant, it is evident that the primary function of "Espressif ESP32-C3-DevKitM-1- 4X Development Board (Microcontroller Development Board)" and the "SOC Product - Espressif ESP32-C3-WROOM-02-N4 Module" is to process and manage data within embedded systems and control independently, without relying on Wi-Fi, Bluetooth, or othe....
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....input/output devices. It is capable of fulfilling the following functions laid down in Note 5 (A) (a) of Chapter 84. Therefore, in view of the aforesaid facts and clarifications, the subject goods are specifically covered under the heading 8471 - Automatic data processing machines and units thereof. The specific heading prevails over the general heading. The subject goods are not covered under 847130, 847141, 847149, & 847150 because it does not contain housing, any input or output devices. The most appropriate heading is 84719000. IV. Further, from the aforesaid grounds/clarifications, it is evident that, the impugned goods are properly and correctly covered under Customs Tariff Heading 8471 and Customs Tariff Item 84719000 of the Customs Tariff Act, 1975, as per Note 3(a) of the General Interpretative Rules (GIR) of the classification of the goods. (B) "SOC_Product-Espressif_ESP32-C3-WROOM-02-N4 _Module" is more appropriately covered under the HS Code 84733010: (I) Applicant submitted that, "SOC Product -Espressif ESP32-C3-WROOM-02- N4 Module" is a part of "Espressif ESP32-C3-DevKitM-1-N4X Development Board (Microcontroller Development Board)".....
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.... Development Board under CTH 8471: As per Chapter Note 5(A) to Chapter 84, an automatic data processing machine must be capable of general-purpose data processing. The subject goods appear to function as embedded programmable controllers intended for incorporation into other equipment and perform specific control/communication tasks. They do not appear to operate as standalone computers and lack essential characteristics of ADP machines such as independent user interface, storage media and general computing environment. Further, Chapter Note 5(E) excludes machines performing specific functions even if incorporating a processing unit. Hence, classification as ADP machine or unit thereof under heading 8471 appears not appropriate. (ii) ESP32-C3-WROOM-02-N4 Module under 8473: The essential character of the goods is derived from the semiconductor microcontroller/SoC mounted on PCB with supporting components. The development board merely facilitates interfacing and testing and does not alter the fundamental character of the electronic module. The goods therefore appear to be Programmable electronic modules based on semiconductor devices used for control and communication functi....
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.... It provides a USB-to-UART bridge, a micro-USB port, for power/programming, and breaks out GPIO pins for interfacing with sensors and other peripheral devices. While it handles wireless communication, it is designed for general application development, not specialized, restricted telecommunication network equipment. c) The subject goods are typically not classified under HS Code 8517 because it is a development tool meant for evaluation and prototyping rather than a finished consumer communication device. (d) In customs and trade classification, HS Heading 8517 generally covers finished products for the transmission or reception of voice, images, or other data, such as smartphones, routers, or IP phones. The ESP32-C3-DevKitM-1 is instead categorized as a microcontroller-based evaluation board. e) Note 4 to Section XVI (Chapters 84-85) of the Harmonized System (HS) defines the classification of functional units. It states that when a machine (or combination of machines) consists of separate components intended to contribute together to a clearly defined function, the whole falls to be classified in the heading appropriate to that function. The Esp....
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....apore. The merchandise under consideration is referred to as an Evaluation Board, PN AD- FMCDAQ2-EBZ: This printed circuit board assembly (PCBA) contains processors, digital to analog converters, analog to digital converters, field programmable gate arrays (FPGA), and input/output connectors. In use, the subject Evaluation Board is described as a design tool having two distinct end uses and is identified first as an "evaluation board" and secondly as a "data acquisition and signal synthesis module". When functioning as an Evaluation Board, the PCBA is connected to an Automatic Data Processing (ADP) machine and various integrated circuits (IC) are tested to assess the performance capabilities of the circuit while providing the user with data to determine how the IC will work within a certain product. When the Evaluation Board is converted to its host ADP machine, it. receives its power from the ADP machine. Furthermore, in this scenario the program required to analyze the IC is running on the ADP machine as well. The instant Evaluation Board is akin to the previously ruled upon PCBAs in HQ H079395, where both connect directly to an ADP machine and each are used for....
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....ect PCBA has two distinct functions, it must first be determined if one of those functions is considered the principal function. Based on the information you have provided as well as its physical description, the way consumers principally use the device, and the manner in which it is marketed, described, and advertised, we find that the essential character of the subject Evaluation Board is accurately described as a printed circuit assembly for the machines of heading 8471, HTSUS. Therefore, we agree with your suggested classification. The applicable subheading for the Evaluation Board, PN AD-FMCDAQ2-EBZ will be 8473.30.1180, HITSUS, which provides for "Parts and accessories ... suitable for use solely or principally with machines of headings 8469 to 8472: Parts and accessories of the machines of heading 8471: Not incorporating a cathode ray tube: Printed circuit assemblies." 16.4 Further, the applicant vide letter dated 19.05.2026 submitted that the subject goods are correctly classifiable under CTH 8542 as per note 3(a) of the General Interpretative Rules (GIR) or 8471 or 8473 of the Customs Tariff Act, 1975. 16.5 Since the Authority for Advance Ruling has....
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.... the Customs Tariff Act is governed by the General Rules for Interpretation (GIR). Rule 1 and Rule 3 of the GIR provides that classification shall be determined according to the terms of the headings and any relevant Section or Chapter Notes. Only when classification cannot be determined under Rule 1 do the subsequent rules become applicable. Therefore, in the present case, it becomes necessary to examine the scope and coverage of Chapter 84 and Chapter 85, along with the relevant HISN Explanatory Notes. 18. The applicant stated that "Espressif ESP32-C3-DevKitM-1-N4X Development Board (Microcontroller Development Board)", in the form it is imported, is for general-purpose use and can be programmed for various applications by installing the software. This development board is not a finished consumer product, but a programmable development board intended for integration into systems or for software and educational use. The Board base material is known as a Printed Circuit Board on which the Integrated Circuits and other electronic active/passive elements are fixed. The subject goods act as the brain of the machines, where it is fixed because it contains a Central Processing Uni....
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....471 60 10 --- Combined input or out put units u Free - --- Printer : 8471 60 24 ---- Graphic printer u Free - 8471 60 25 ---- Plotter u Free - 8471 60 29 ---- Other u Free - 8471 60 40 --- Keyboard u Free - 8471 60 50 --- Scanners u Free - 8471 60 60 --- Mouse u Free - 8471 60 90 --- Other u Free - 8471 70 - Storage units : 8471 70 10 --- Floppy disc drives u Free - 8471 70 20 --- Hard disc drives u Free - 8471 70 30 --- Removable or exchangeable disc drives u Free - 8471 70 40 --- Magnetic tape drives u Free - 8471 70 50 --- Cartridge tape drive u Free - 8471 70 60 --- CD-ROM drive u Free - 8471 70 70 --- Digital video disc drive u Free - 8471 70 90 --- Other u Free - 8471 80 00 - Other units of automatic data processing machines u Free - 8471 90 00 - Other u Free - ....
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....elevision cameras, digital cameras and video camera recorders; (v) Monitors and projectors, not incorporating television reception apparatus. (E) Machines incorporating or working in conjunction with an automatic data processing machine and performing a specific function other than data processing are to be classified in the headings appropriate to their respective functions or, failing that, in residual headings. I find that the ESP32-C3-DevKitM-1-N4X is a development board, consisting of a microcontroller (CPU and memory), printed Circuit Board with mounted components and interfaces and communication capability. As per Chapter Note 6 (A) to Chapter 84, an ADP machine must Store processing programs, be freely programmable, perform arithmetic computations and execute processing logic automatically. The applicant contends that the development board contains CPU. memory, processes data from sensors and executes instructions. Therefore, qualifies as an ADP system/unit. The ESP32-C3-DevKitM-1-N4X is a standalone embedded system, not a peripheral unit, does not function as part of a conventional ADP system and does not require Monitor, Keyboard, storage system and o....
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....pally to be used with ADPM and also, not an essential component of ADPM without which ADPM will not be functional, hence, cannot be classified under CTH 8473 as a part. Therefore, as per Note 6 (D), Heading 84.71 does not cover the Apparatus for the transmission or reception of voice, images or other data, including apparatus for communication in a wired or wireless network (such as a local or wide area network); when presented separately, even if they meet all of the conditions set forth in Note 6 (C) above: and according to Note 6(E) to chapter 84, machines incorporating or working in conjunction with an automatic data processing machine and performing a specific function other than data processing are to be classified in the headings appropriate to their respective functions or, failing that, in residual headings. Since, the product is not an ADP machine nor a unit of ADP system and it performs embedded control functions. Therefore, CTH 8471/8473 are NOT applicable. 19. Further, the applicant stated about second item that the "SOC Product -Espressif ESP32-C3- WROOM-02-N4 Module" contains a microprocessor - A 32-bit RISC-V single-core processor. It is solely and principally....
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....ines incorporating or working in conjunction with an automatic data processing machine and performing a specific function other than data processing are to be classified in the headings. appropriate to their respective functions or, failing that, in residual headings. The subject ESP32-C3-WROOM-02-N4 module does not satisfy these conditions as it is an independent embedded module capable of processing and transmitting data. Further, Chapter Note 6(E) provides that machines performing a specific function other than data processing are to be classified according to their respective function, even if they incorporate an ADP machine. The subject module performs wireless communication functions (Wi-Fi/Bluetooth) and therefore stands excluded from Heading 8473. 20. Before deciding the classification of the subject goods i. e. ESP32-C3-DevKitM-1-N4X, it is necessary to understand about ESP32. The Arduino boards are used as development board, built around basic microcontrollers intended for control-oriented applications, involving input/output interfacing with sensors and actuators, without any inherent capability for wireless communication; such connectivity, if required, is achieve....
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....t formed, for example, by a printed circuit; therefore, the subject goods ESP32-C3-DevKitM-1-N4X development board, having ESP32 Module, Wi-fi, Bluetooth, Antenna, Oscillator, Voltage regulator, GPIO Pins, Reset and Boot Buttons, Power LED mounted on Printed Circuit Boards are excluded from the scope of heading 8542. Further, the subject goods are primarily used in IoT (Internet of Things) applications for sensing, processing, and communication. The product contains in-built Wi-Fi and Bluetooth modules i.e. ESP32-C3-MINI-1 or ESP32-C3-MINI-1U which is a fully integrated wireless communication module. The module is designed for direct integration into electronic devices without the need for additional RF design or circuitry, and is capable of independently performing processing, transmission, and reception of data over Wi-Fi and Bluetooth networks. These SoCs are deployed precisely for transmitting and receiving data over wireless communication in IoT ecosystems which is also confirmed by the applicant. Thus, its primary function is to transmit and receive data wirelessly. the inbuilt and primary feature of wireless communication, enabling connectivity to external networks withou....
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....ntegrates RF filters, Automatic Gain Control (AGC), DC offset cancelation circuits, and baseband filters. 4.3.1.2 The 2.4 GHz transmitter modulates the quadrature baseband signals to the 2.4 GHz RF signal, and drives the antenna with a high-powered CMOS power amplifier. The use of digital calibration further improves the linearity of the power amplifier. Additional calibrations are integrated to cancel any radio imperfections, such as: * Carrier leakage * I/Q amplitude/phase matching * Baseband nonlinearities * RF nonlinearities * Antenna matching These built-in calibration routines reduce the cost, time, and specialized equipment required for product testing. 4.3.1.3 Clock Generator The clock generator produces quadrature clock signals of 2.4 GHz for both the receiver and the transmitter. All components of the clock generator are integrated into the chip, including inductors, varactors, filters, regulators and dividers. The clock generator has built-in calibration and self-test circuits. Quadrature clock phases and phase noise are optimized on chip with patented calibration algorithms which ensure the best per....
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.... Bluetooth Low Energy radio and PHY in ESP32-C3 support: * I Mbps PHY * 2 Mbps PHY for higher data rates * Coded PHY for longer range (125 Kbps and 500 Kbps) * HIW Listen before talk (LBT) 4.3.3.2 Bluetooth LE Link Controller Bluetooth Low Energy Link Layer Controller in ESP32-C3 supports: * LE Advertising Extensions, to enhance broadcasting capacity and broadcast more intelligent data * Multiple advertising sets. * Simultaneous advertising and scanning * Multiple connections in simultaneous central and peripheral roles * Adaptive Frequency Hopping (AFH) and channel assessment * LE Channel Selection Algorithm #2 * Connection parameter update * High Duty Cycle Non-Connectable Advertising * LE privacy 1.2 * LE Data Packet Length Extension * Link Layer Extended Scanner Filter policies * Low duty cycle directed advertising * Link layer encryption * LE Ping From the above, it is clear that transmission and reception of data is not incidental but a built-in and defining capability of the subject goods. The subject pr....
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....upportive thereto. Hence, the subject goods are appropriately aligned with the scope and coverage of Heading 8517. 21 Further, I find that the product ESP32-C3-DevKitM-I-N4X Development Board incorporating the: ESP32-C3 system-on-chip through the ESP32-C3-MINI-1 modulo, and functions as a programmable embedded platform providing integrated wireless communication capabilities, namely Wi-Fi: (2.4 GHIz) and Bluetooth Low Energy (BLE), along with microcontroller-based data processing. It facilitates transmission and reception of data in IoT applications, while also enabling interfacing with external peripherals through standard protocols such as I2C, SPI and UART via exposed GPIOs: The board further includes ancillary features such as USB-based programming and debugging interface, voltage regulation and boot/reset circuitry, which collectively support firmware development, testing and prototyping. The principal function of the subject goods is derived from the integrated ESP32-C3- MINI-I module, which incorporates a 2.4 GHZ RF transceiver enabling Wi-Fi and Bluetooth Low Energy (BLE) communication, thereby allowing transmission and reception of data over wireless networks. The em....
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....mages or other data, including apparatus for communication in a wired or wireless network (such as a local or wide area network): 8517 61 00 -- Base stations u 20% - 8517 62 -- Machines for the reception, conversion and transmission or regeneration of voice, images or other data, including switching and routing apparatus: 8517 62 10 --- PLCC equipment u Free - 8517 62 20 --- Voice frequency telegraphy u Free - 8517 62 30 --- Modems (modulators-demodulators) for xDSL based Wireline Telephony u Free - 8517 62 50 --- Digital loop carrier system(DLC) u Free - 8517 62 60 --- Synchronous digital hierarchy system(SDH) u Free - 8517 62 70 --- Multiplexers, statistical multiplexers for PDH based Wireline Telephony u Free - 8517 62 90 --- Other u 20% - 8517 69 -- Other: 8517 69 10 --- ISDN System u Free - 8517 69 20 --- ISDN terminal adaptor u Free - 8517 69 40 --- X 25 Pads u Fr....
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.... configured, for example, as public switched telephone networks, Local Area Networks (LAN), Metropolitan Area Networks (MAN) and Wide Area Networks (WAN), whether proprietary or open architecture. This group includes : (1) Network interface cards (e.g., Ethernet interface cards). (2) Modems (combined modulators-demodulators). (3) Routers, bridges, hubs, repeaters and channel to channel adaptors. (4) Multiplexers and related line equipment (e.g., transmitters, receivers or electro-optical converters). (5) Codecs (data compressors/decompressors) which have the capability of transmission and reception of digital information. (6) Pulse to tone converters which convert pulse dialled signals to tone signals. In view of the above, I observed that the ESP32-C3-DevKitM-1-N4X development board is built around the ESP32-C3 system-on-chip, mounted in the form of the ESP32-C3-MINI-1 module. It is a fully assembled programmable platform that integrates a 2.4 GHz RF transceiver enabling Wi-Fi and Bluetooth Low Energy (BLE) communication, along with a microcontroller for executing firmware. The board exposes GPIOs for interfacing wi....
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....WM controller, general DMA controller, TWAI(r) controller, temperature sensor, ADC, and up to 22 GPIOs. It also includes SPI, Dual SPI and Quad SPI. interfaces. Its essential character derives from radio communication/transmission functionality. The Chapter heading 8542 covers electronic integrated circuits as such. The applicant's products are not bare semiconductor devices, but assembled electronic modules/boards with multiple components. Therefore, classification under heading 8542 is not sustainable. Also, as per the HSN explanatory notes to heading 8542, the heading excludes assembly formed by (a) Mounting one or more discrete components on a support formed, for example, by a printed circuit; therefore, the subject goods ESP32-C3-WROOM-02-N4 module, having ESP32 Module, Wi-fi, Bluetooth, Antenna, Oscillator, Voltage regulator, GPIO Pins, Reset and Boot Buttons, Power LED mounted on Printed Circuit Boards are excluded from the scope of heading 8542. It contains a CPU and its principal function is. wireless communication (data transmission /reception). Accordingly, the product is correctly classifiable under CTH 8517 62 90. Relevant Chapter heading 8517 is under: 8517 ....
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....e - 8517 69 20 --- ISDN terminal adaptor u Free - 8517 69 40 --- X 25 Pads u Free - 8517 69 60 --- Set top boxes for gaining access to internet for Wireline Telephony u Free - 8517 69 70 --- Attachments for telephones u Free - 8517 69 90 --- Other u *20% - - Parts: 8517 71 00 -- Aerials and aerial reflectors of all kinds; parts suitable for use therewith u 20% - 8517 79 -- Other: 8517 79 10 --- Populated, loaded or stuffed printed circuit boards u 20% - 8517 79 90 --- Other u 15% - In terms of Section Note 3 to Section XVI, composite machines are to be classified according to their principal function. The ESP32-C3-WROOM-02-N4 module performs the principal function of wireless data transmission and reception and is therefore classifiable under CTI 8517. CTH 851762 covers Machines for the reception, conversion and transmission or regeneration of voice, images or other data, including switching and routing apparatus. From the plain readin....