Tariff Classification Advance Ruling
Canine safety light


Scott Henry
RC Products Ltd.
550 East Kent Avenue South
Vancouver, BC V5X 4V6

Date of issuance of ruling: May 29, 2015

This is in response to your request for an advance ruling on the tariff classification of a canine safety light, on behalf of your client, R.C. Products Ltd.  This product is manufactured by Guanzhou Jianmin Plastic Factory of Guangzhou, China.

TRS Number: 270064
Classification Number: 8531.80.00.90
Effective Date: May 29, 2015

Product Description

The Canine Safety Light is composed of a plastic casing, an LED light and is powered operates by two CR2032 coin cell batteries.  The light dual functions of flashing or steady on and is engaged by twisting the plastic casing.  The light is waterproof and can be clipped onto a dog's collar or leash or on to a backpack.

Analysis and Justification

General Explanatory Note (A)(3) to Chapter 85 states that "This Chapter covers…Certain machines and appliances which depend for their operation on the properties or effects of electricity, such as its electro-magnetic effects, heating properties, etc. (headings 85.05, 85.11 to 85.18, 85.25 to 85.31 and 85.43)."

Heading 85.31 provides for electric sound or visual signaling apparatus (for example, bells, sirens, indicator panels, burglar or fire alarms), other than those of heading 85.12 or 85.30. The Explanatory Notes to heading 85.31 states, in pertinent part, "this heading covers all electrical apparatus used for signaling purposes, whether using sound for the transmission of the signal (bells, buzzers, hooters, etc.) or using visual indication (lamps, flaps, illuminated numbers, etc.), and whether operated by hand (e.g., door bells) or automatically (e.g., burglar alarms).  The Canine Safety Light conforms to the terms of Heading 85.31 and is classified therein.


Section 10 of the Customs Tariff directs that classification of imported goods shall be determined in accordance with the General Rules for the Interpretation of the Harmonized System.    Section 11 of the Customs Tariff states that in interpreting the headings and subheadings, regard shall be had to the World Customs Organization's (WCO) Explanatory Notes to the Harmonized Commodity Description and Coding System.

General Interpretative Rule 1 (GIR 1) directs that titles of Sections, Chapters and sub-Chapters are provided for ease of reference only.  For legal purposes, classification shall be determined according to the terms of the heading and any relative Section and Chapter Notes.  Similarly, General Interpretative Rule 6 (GIR 6) directs that classification shall be determined according to the terms of those subheadings and any related Subheading Notes.

The Canine Safety Light is classified under 8531.80.00.90 as other visual signaling apparatus, in accordance with General Interpretative Rule 1. 

Legislative/Administrative References

This ruling has been issued under paragraph 43.1(1)(c) of the Customs Act and will be honoured by the CBSA for future importations of the products specified, provided the material facts and circumstances remain as originally presented; all conditions in the ruling have been met; the ruling has not been modified, revoked, revised, or cancelled; and the Customs Tariff legislation has not changed.  Should there be a change in the material facts or circumstances pertaining to the products, you must notify the CBSA as soon as possible.  You may request that the advance ruling be modified or revoked as of the date of the change.

Importers should quote the advance ruling number at the time of importation in either the description field of the B3 entry document or on the Canada Customs Invoice.  Exporters or producers should quote the advance ruling number on the Certificate of Origin or commercial invoice accompanying the products.

Should you disagree with this advance ruling, you may file a dispute notice under subsection 60(2) of the Customs Act within 90 days of the date of issuance.  Please see the procedures outlined in Appendix C of the CBSA's Memorandum D11-11-3, Advance Rulings for Tariff Classification.

This advance ruling is considered 'reason to believe' for the purposes of section 32.2 of the Customs Act and the CBSA's Administrative Monetary Penalty System, described in Memorandum D22-1-1.

All Memoranda referenced in this letter may be accessed on the CBSA website.

Consent to the Public Release of the Advance Ruling

As per your consent statement, we will release this advance ruling to the public, in both official languages, in accordance with the procedures described in Memorandum D11-11-3. The ruling will be published on the CBSA website in 30 days.

CBSA Contact

Mark Grant
Manager, Tariff Policy Unit 'B'
Trade Policy Division
Headquarters, Ottawa

File Number


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