## Facts

- Universal Electronics, Inc. imported programmable hand-held remote-control units used to operate televisions, stereos, and other appliances equipped with infrared receivers.
- The remotes contained a microprocessor, infrared LEDs, and a software database of infrared command codes; users configured the remote by entering a code matching the appliance brand/type.
- When a user pressed a key, the remote’s microprocessor, powered by a battery, selected the appropriate command sequence and drove the LEDs to emit infrared pulses in that pattern.
- The target appliance received the infrared pulses, converted them to an electrical signal for its microprocessor, and used electricity to perform the requested function (e.g., volume increase).
- Customs classified the merchandise under HTSUS subheading 8537.10.00 (“boards, panels … and other bases … for electric control or the distribution of electricity”).
- Universal protested, asserting classification instead under HTSUS 8543.80.90 (“other electrical machines and apparatus”) or 8531.80.00 (“electric sound or visual signaling apparatus”).
- The Court of International Trade upheld Customs’ classification; Universal appealed to the Federal Circuit.

## Issues

1. In a tariff classification dispute with no material factual disagreement, what role (if any) does the presumption of correctness for Customs’ classification play?
2. Whether programmable infrared remote controls are “other bases … for electric control” under HTSUS 8537.10.00, or instead fall under HTSUS 8543.80.90 or 8531.80.00 because they transmit an intermediary (infrared) signal.

## Decision

- The Federal Circuit affirmed the Court of International Trade.
- The court applied the two-step classification approach: (1) construe the relevant tariff terms (law) and (2) determine whether the merchandise fits the construed terms (fact).
- Because the material facts were undisputed, the court treated the dispute as primarily legal and resolved it on the proper interpretation and application of HTSUS 8537.10.00.
- The court held the remotes were properly classified under HTSUS 8537.10.00 as “other bases … for electric control.”
- The court rejected classification under HTSUS 8543.80.90 and 8531.80.00.

## Legal Principles

- Tariff classification follows a two-step method: interpretation of tariff language is reviewed as a question of law, while fitting the goods to the construed terms is generally factual.
- “For electric control” in HTSUS 8537 is not limited to devices where electricity directly produces the ultimate controlled result within the same unit; electrically powered devices that generate control signals used to direct electrical functions in another device can qualify.
- Where a heading specifically describes the merchandise’s essential function (here, electric control), it prevails over residual “other” provisions such as HTSUS 8543.
- An apparatus is not classified as “sound or visual signaling” under HTSUS 8531 when its signal (e.g., infrared pulses) is primarily instrumental to controlling electrical operations of another device rather than providing signaling as an end function.

## Conclusion

The Federal Circuit upheld Customs’ classification of programmable infrared remote controls under HTSUS 8537.10.00, concluding that the remotes function as bases “for electric control” despite using infrared transmission as an intermediate step, and that this specific heading controls over broader alternative provisions.


Universal Elecs., Inc. v. United States, 112 F.3d 488 (Fed. Cir. 1997)