In ruling NY N306236, Customs and Border Protection (CBP) discusses the classification of a dog training collar device made by Garmin Sport Pro. The device is retail packaged with a correction module, collar, handheld transmitter, and an A/C charging adapter with cable. In use, the correction module is attached to the dog’s neck via the collar, which allows the metal contact points to meet the skin. The handheld transmitter is then used by the owner to deliver a corrective notification in the form of a vibration or electric nerve stimulation when any unwanted behavior is witnessed. The training device can also automatically track the number of times the dog barks and deliver a corrective notification when a predetermined number of barks is reached.

The set, as described above, meets the definition of “goods put up in sets for retail sale” as set forth in General Rule of Interpretation (GRI) 3(b). GRI 3(b) provides that such sets are classified by the component that imparts the essential character. It is the opinion of CBP that the correction module imparts the essential character. As the module incorporates multiple functions, both correction and tracking, it is considered a composite machine and CBP believes it should be classified pursuant to Note 3 to Section XVI of the HTSUS by the principal function of the unit. The ability to correct the dog’s behavior, either automatically or manually via the handheld transmitter, is the principal function in the view of CBP. The ability to count and display the number of barks is a secondary feature that does not merit equal consideration along with the training capability.

CBP determined that the applicable subheading for the item is 8543.70.9960 HTSUS, which provides for “Electrical machines and apparatus, having individual functions, not specified or included elsewhere in this chapter; parts thereof: Other machines and apparatus: Other: Other: Other: Other.” The general rate of duty will be 2.6% ad valorem.