Dual-port USB wall charger, 20W USB-C power delivery plus USB-A, with folding prongs

GRI Reasoning

Step 1 – GRI 1: Heading Identification

The product is a dual-port (USB-C PD 20 W + USB-A) AC-to-DC wall charger with folding prongs. Its essential and primary function is converting AC mains voltage to regulated DC output — the textbook definition of a static converter (rectifier). Heading 8504 ('Electrical transformers, static converters (for example, rectifiers) and inductors; parts thereof') covers this product under GRI 1. Heading 8544 (insulated wire/cable) is inapplicable; the product's essential character is power conversion, not electrical conduction. Candidate code 8544.42.90 is eliminated.

Step 2 – GRI 1: Subheading Navigation within 8504

• 8504.40 – 'Static converters': confirmed applicable (AC→DC rectification).
• Three candidate subheadings within 8504.40:
• 8504.40.85 – 'For telecommunication apparatus' (general rate: Free)
• 8504.40.95 – 'Other' (general rate: Free)
• 8504.40.60 / 8504.40.70 – Power supplies for ADP machines (heading 8471) or specific monitors/printers: not applicable for a general USB wall charger not designed for physical incorporation into an ADP machine.

Step 3 – 8504.40.85 vs. 8504.40.95

Rulings H342570, H342571, and H344006 (all July 21, 2025) directly address wall chargers with USB-A and USB-C ports (including an 'Xtreme Power' sample with 2.4A, USB-C + USB-A — nearly identical to the subject merchandise). CBP liquidated those goods under 8504.40.95 ('Other'), rejecting the protestant's argument for 8504.40.85 ('for telecommunication apparatus'). The rulings confirm that multi-port USB wall chargers of this type — general-purpose, capable of charging smartphones, tablets, and other devices — are classified under 8504.40.95, not 8504.40.85. The protestant's 8504.40.85 claim remained unresolved in the excerpted ruling text, but CBP's liquidation position (8504.40.95) is the operative binding classification used.

Step 4 – 10-Digit Statistical Suffix

Within 8504.40.95, the product is a power supply (rectifier/rectifying apparatus), not an inverter. Total rated output is 20 W (USB-C PD) plus USB-A (unspecified, typically ≤5–12 W) — aggregate output well under 50 W. The applicable statistical breakout is 8504.40.95.10 ('Power supplies: With a power output not exceeding 50 W'), which appears in the verified HTS rows.

Step 5 – Duty Rate

• General (Column 1): Free (as shown in 8504.40.95 row)
• Column 2 (Other): 35% (China is Column 1, not Column 2, so this does not apply)
• Section 301 Additional Duty: 8504.40.95 carries footnote referencing 9903.88.03, which imposes 'the duty provided in the applicable subheading plus 25%' for Chinese-origin goods. Effective duty = Free + 25% = 25% ad valorem (subject to any applicable exclusion).

Step 6 – Section 301 Exclusion Analysis (9903.88.67)

U.S. Note 20(mm)(32) provides an exclusion for 'Static converters of a kind used to charge telecommunication apparatus in cars or homes, valued not over $2 each (described in statistical reporting number 8504.40.8500).' The subject merchandise has a declared unit value of $3.10, which exceeds the $2.00 cap. Therefore, even if the product were classified under 8504.40.85 (and described by 8504.40.8500), it would not qualify for the 9903.88.67 exclusion based on value alone. The full Section 301 additional duty of 25% (via 9903.88.03) is expected to apply.

Step 7 – Duty Summary

| Component | Rate |

|---|---|

| Column 1 General | Free |

| Section 301 (9903.88.03) | +25% |

| Effective total | 25% |

Step 8 – Ruling Analogy Summary

H342570, H342571, and H344006 are highly analogous: same product type (plastic AC-DC USB wall charger, USB-A + USB-C ports), same origin (China), same classification outcome (8504.40.95 + 9903.88.03). These are the most directly on-point rulings in the supplied evidence.