Keyboard parts are hit by the new Trump China tariffs

I’m in favor. Just start a new thread with what you’ve got and at-mention me and I’ll turn it into a wiki-post that anyone can edit. :slight_smile:

2 Likes

Regarding HS Codes, Canada Post has a useful tool for searching through the list. It does a pretty good job at providing the proper code for everything.

https://www.canadapost.ca/cpotools/apps/wtz/business/findHsCode?execution=e1s1

8473.30 - Generic keyboard parts, stabilizers, keycaps, PCBs even, etc. Very useful “generic” keyboard parts HS Code.
8536.50 - Switches
3403.99 - Lube

6 Likes

I don’t really have any insight to add. The more you look at it, the crazier it gets. For instance, this ruling classifies what appear to be partially-assembled keyboards as

8537.10.90, HTSUS, as: “Boards, panels, consoles, desks, cabinets and other bases, equipped with two or more apparatus of heading 8535 or 8536, for electric control or the distribution of electricity … : For a voltage not exceeding 1,000 V: … Other.”

Then goes on to classify printed and non-printed “keytops” (aka keycaps) as two different codes, neither of which match the ones someone posted earlier in this thread:

The printed keytops separately imported by Preh are classified in subheading 8538.90.80, HTSUS, as: “Parts suitable for use solely or principally with the apparatus of heading 8535, 8536 or 8537: … Other: … Other: … Other.”

The unprinted or interchangeable keytops which do not contain electrical connectors are classified in subheading 8485.90.00, HTSUS, as: “Machinery parts, not containing electrical connectors, insulators, coils, contacts or other electrical features, and not specified or included elsewhere in this chapter: … Other.”

If there are unprinted or interchangeable keytops which include electrical connectors, they are classified in subheading 8548.90.00, HTSUS, as “… electrical parts of machinery or apparatus, not specified or included elsewhere in this chapter: … Other.”

Here is another ruling, which has several interesting classifications. In particular, Sample B, sounds like a keyboard PCB, and gets classified as 8741.60.20 (which would not fall under the new tariffs).

Samples B and C1, on the other hand, are connectable to the central processing unit, and are specifically designed as parts of an ADP system. Sample B has many (somewhat condensed) features that are similar to a standard PC keyboard. It is a QWERTY-style keyboard with interface electronics but no housing. It has twelve function keys and includes three LEDs, which appear to correspond to the “numbers lock,” “caps lock” and “scroll lock” portion of a standard PC keyboard.

Samples B and C1 are classifiable under subheading 8471.60.20, HTSUS, which provides for keyboards for ADP machines.

I’m researching all of this for a story on Keychatter. Seems there’s a lot of confusion, and a lot of nuance. And FWIW, if anyone is working up some details for lists, etc., I’d love to post those on Keychatter as a reference if it helps.

I look forward to reading it! I’m not an expert in HTS classification, but I’ve been through the process enough to know that it’s generally very murky and every ruling is always highly contested, as there is oftentimes a lot of money at stake when it comes to products made by large corporations. Let me know if there is anything I can do to help.

Does this apply to manufacturing origin or shipping origin? I mean, could you reduce the cost penalty by shipping to an adjacent country first (e.g. India, Vietnam, etc.) and then have getting shipped to the US?

Country of manufacturing origin is the correct source of classification, but these days that can be pretty complicated since many products are made from parts made in different countries.