HS Codes for Electronics: Chapter 84, 85, and 91 Explained

You source a product. It runs on a battery, has a screen, connects to the internet. You call it electronics. So you file it under Chapter 85 — where most electronics live.

But your laptop is in Chapter 84. Your smartwatch is in Chapter 91. And your smartphone, despite doing many of the same things as a laptop, is in Chapter 85.

This guide explains why HS code classification for electronics does not follow the product name — and what determines the correct chapter before you file.

Why isn't there one chapter for all electronics?

The Harmonized System (HS), maintained by the World Customs Organization (WCO) and used by over 200 countries, classifies goods by principal function — not by what they're made of or what they're called. Electronics is a material category, not a customs category. A product that runs on electricity can belong to dozens of different chapters depending on what it primarily does.

The two chapters most associated with electronics are:

• Chapter 84: Machinery and mechanical appliances, including computers and data processing equipment

• Chapter 85: Electrical machinery and equipment, including communication apparatus, semiconductors, and consumer electronics

But electronics also appear in Chapter 90 (measuring instruments), Chapter 91 (clocks and watches), and others — depending on function.

What is the difference between Chapter 84 and Chapter 85 for electronics?

The boundary comes down to one question: does the device primarily process data, or does it primarily transmit and receive signals? According to the WCO HS Nomenclature and the U.S. International Trade Commission (USITC) Harmonized Tariff Schedule (HTS), Chapter 84 covers automatic data processing machines, while Chapter 85 covers electrical communication apparatus.

In practice:

• Laptop / Tablet → HS 8471.30 (Chapter 84). Principal function: computing. A laptop stores and executes programs independently, with its own CPU, keyboard, and display. That makes it a data processing machine, not a communication device.

• Smartphone → HS 8517.12 (Chapter 85). Principal function: transmitting and receiving voice and data. According to WCO Chapter Notes, heading 8517 covers apparatus for transmission or reception of voice, images, or other data — including devices communicating in wireless networks.

The confusion starts because modern devices do both. A laptop connects to WiFi. A smartphone runs apps. But classification is based on the primary function — not every function the device performs.

Why does a smartwatch go to Chapter 91, not Chapter 85?

This is where the principal function rule becomes most visible. A smartwatch syncs to your phone, receives notifications, tracks health data, and connects via Bluetooth. Under heading 8517, that sounds like communication apparatus.

But according to WCO classification guidance, Chapter 91 governs all clocks and watches and parts thereof — including smart models. The wireless connectivity and data functions are secondary features. The device's principal function remains timekeeping. That puts it in Chapter 91, regardless of its electronic capabilities.

As the WCO explanatory notes make clear, Section XVI Note 3 — which governs multi-function machines in Chapters 84 and 85 — does not override a more specific heading elsewhere in the tariff. Chapter 91 is more specific for watches. It takes priority.

What about devices that do multiple things equally?

When a device has no single dominant function, Chapter 84's heading 8479 applies as the catch-all for "machines having individual functions, not specified or included elsewhere." But reaching 8479 requires ruling out all more specific headings first.

According to the USITC HTS Chapter 84 Notes, when a composite machine performs a specific function covered by a heading in Chapter 84 or 85, it is classified under that heading — not split across multiple codes. The classification follows the heading that best describes the machine's primary purpose.

How do you apply this before you file?

Ask two questions before classifying any electronic product:

• What does it primarily do? Compute, communicate, measure time, or measure physical quantities?

• Is there a more specific chapter outside 84 and 85? Watches go to 91. Optical instruments go to 90. Chapter 85 is not the default for anything with a battery.

For recurring or high-value shipments, a binding ruling eliminates the guesswork. The U.S. CBP offers free rulings through the CROSS system (Customs Rulings Online Search System). The EU offers BTI (Binding Tariff Information), valid for three years. One ruling now prevents reclassification disputes later.

Quick reference: electronics HS classification by function

• Laptop / Tablet → HS 8471.30 (Chapter 84) — data processing machine

• Smartphone → HS 8517.12 (Chapter 85) — communication apparatus

• Smartwatch → Chapter 91 — timekeeping device

• Semiconductor / IC → HS 8542.31 (Chapter 85) — electronic integrated circuit

• Bare PCB → HS 8534.00 (Chapter 85) — printed circuit

• Assembled PCB (by function) → Chapter 84 or 85, based on the end device

• Multi-function device, no dominant function → HS 8479 (Chapter 84)

The product name tells you what to call it. The principal function tells you where to classify it. For electronics, those are rarely the same thing.