Braided nylon USB-C to USB-C charging and data cable, 2 meters, with aluminum connector housings

GRI Reasoning

Step 1 – GRI 1: Heading Identification

The product is a 2-meter braided nylon insulated cable with aluminum-housed USB-C connectors at each end, carrying both power (charging) and data signals at voltages well below 1,000 V. The tariff schedule provides directly at Heading 8544: *"Insulated wire, cable and other insulated electric conductors, whether or not fitted with connectors."* This description encompasses the product by its terms. No other heading is more specific for a complete cable assembly fitted with connectors:

• 8473 (parts/accessories for ADP machines): Note 2(b) to Section XVI excludes goods classifiable in Chapter 85 from being classified as parts/accessories. The cable is an insulated conductor of Chapter 85, so 8473 is excluded.
• 8536 (connectors/plugs): The cable assembly as a whole is not merely a connector or plug; it is an insulated conductor fitted with connectors. GRI 3(b) essential character of the complete assembly is the cable conductor, not the housing alone.

GRI 1 directs classification to Heading 8544.

Step 2 – GRI 6: Subheading Selection

Within 8544, the relevant branch is:

• 8544.42: *Other electric conductors, for a voltage not exceeding 1,000 V: Fitted with connectors* — ✓ USB-C cables operate at USB voltages (5V–20V), well below 1,000 V, and are fitted with USB-C connectors.

Within 8544.42, two subheadings compete:

• 8544.42.10.00: Fitted with modular telephone connectors — ✗ USB-C is not a modular telephone (RJ) connector.
• 8544.42.20.00: *Of a kind used for telecommunications* — Possible; USB-C carries data signals.
• 8544.42.90: *Other* — The residual subheading.

Step 3 – Telecommunications vs. Other

CBP rulings show a fact-specific split:

| Ruling | Product | Classification |

|---|---|---|

| N007536 (2007) | USB-A to USB-B cable, connects PC to USB devices, data/music transfer | 8544.42.9000 |

| N009187 (2007) | USB cable for iPod (data + charging) | 8544.42.9000 |

| N070895 (2009) | USB cable for data transfer + battery charging (digital photo frame) | 8544.42.2000 |

| N356502 (2025) | USB-C cable for aviation headsets (audio, phone calls, charging, data) | 8544.42.2000 |

The telecom classification in N070895 and N356502 appears linked to specific connectivity functions (photo/data transfer framed as telecom, or explicit audio/voice/navigation use). The subject cable is described generically as a "charging and data cable" with no specialized telecom context. N007536 and N009187 — both involving general-purpose USB cables connecting PCs to consumer devices — classified identical-function products under 8544.42.9000. Those rulings are more analogous to the subject merchandise.

Primary recommendation: 8544.42.90.90 (Other — not an extension cord per statistical note 7). General rate: 2.6%.

Alternative to verify: 8544.42.20.00 — Free duty, but requires CBP confirmation that this cable is "of a kind used for telecommunications."

Step 4 – Chapter 99 Overlay (China Origin)

The footnote on 8544.42.90 references 9903.88.03, which carries an additional duty overlay for Chinese-origin goods. The rate under 9903.88.03 is described as "the duty provided in the applicable subheading plus" an additional percentage — importers must verify the current 9903.88.03 rate at entry. Footnote on 8544.42.90.90 also references 9903.88.69 (a possible exception/carve-out heading); this must be checked for applicability. These are overlay flags, not independently confirmed rates from this evidence.

Note: 8544.42.20.00 also carries footnotes for 9903.88.03 and 9903.88.69 — same overlay structure.

Step 5 – Duty Summary (Base Rates Only)

| Code | General Rate | Column 2 Rate | Notes |

|---|---|---|---|

| 8544.42.90.90 | 2.6% | 35% | 9903.88.03 overlay flag; 9903.88.69 flag on stat suffix |

| 8544.42.20.00 | Free | 35% | 9903.88.03 overlay flag; 9903.88.69 flag |

Step 6 – Rejected Alternatives

• 8473.30.5100: Excluded by Section XVI Note 2(b); the cable is classifiable in Chapter 85.
• 8536.90.8085: The cable assembly's essential character is the insulated conductor, not the connector housing alone; 8544 specifically covers conductors fitted with connectors and is more specific under GRI 3(a).