Universal Electronics, Inc. v. United States
United States Court of Appeals for the Federal Circuit
112 F.3d 488 (1997)
- Written by Gonzalo Rodriguez, JD
Facts
Universal Electronics, Inc. (Universal) (plaintiff) imported remote controls that could be configured for use with different home appliances. The United States Customs Service (customs) (defendant) classified the remotes as “boards, panels . . . and other bases . . . for electric control” under subheading 8537.10.00 of the Harmonized Tariff Schedule of the United States (HTSUS). Universal challenged customs’ classification, arguing that the remotes were not devices for electric control and instead should have been classified as other “electrical machines” under subheading 8543.80.90 or as “electric sound or visual signaling apparatus” under subheading 8531.80.00. The Court of International Trade upheld customs’ classification, citing the statutory principle that customs’ tariff classification is entitled to a presumption of correctness and stating that subheading 8537.10.00 covered a broad range of items, including items like the remotes for which electricity caused the desired result to occur. Universal appealed, arguing that the statutory presumption of correctness did not apply because there was no factual dispute between the parties. Further, Universal argued that the use of “electric control” in the subheading indicated that electricity must directly cause the desired result rather than sending an intermediary signal that triggered the result.
Rule of Law
Issue
Holding and Reasoning (Clevenger, J.)
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