The tariff classification of HitClips™ Micro Music System from China

NY G82214 October 11, 2000 CLA-2-95:RR:NC:SP:225 G82214 CATEGORY: Classification TARIFF NO.: 9503.50.0020 Susan Abatal Hasbro, Inc. 1027 Newport Ave. Pawtucket, RI 02862 RE: The tariff classification of HitClips™ Micro Music System from China Dear Ms. Abatal: In your letter dated September 6, 2000, received in this office September 14, 2000, you requested a tariff classification ruling on behalf of Tiger Electronics. HitClips™ Micro Music System is a series of sound producing items. Each retail package will include a cartridge that stores and controls data of sound and a player that provides the interface and transduction of the sound. The cartridge is a computer integrated circuit or chip that stores and transmits signals producing sound, which will be a one minute recording of a well known song. The players, miniature in size, will resemble boomboxes, disc players, etc. One player is also an alarm clock. Without a sample, it is not possible to rule on it. The players will only work with the HitClip™ and visa versa. Two samples were provided. The first, Rockin’ Micro Boombox, is a three inch wide, two inch high, and inch and a half deep version of a boombox. The Hitclip™ is inserted at the top and there is a play button. The second, Micro Personal Player, is an inch and a quarter wide, inch and a half high and inch deep version of a personal disc player with one earpiece. The Hitclip™ is inserted in the front and there is a small play button. Given the size and limited capacity of the two sample players, there is no question they are toys. However, we are unable to response on the classification of the HitClip™ itself as that issue is presently under discussion within the Customs Service. If the Hitclip™ is considered sound recording media, Chapter 85 Note 6 requires separate classification. If the Hitclip™ is not media, then it will be considered a toy part when retail packed with the player. The applicable subheading for the two sample players of the HitClips™ Micro Music System will be 9503.50.0020, Harmonized Tariff Schedule of the United States (HTS), which provides for Other toys:…:Toy musical instruments and apparatus and parts and accessories thereof. Instruments and apparatus. The rate of duty will be free. This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177). A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist Alice Wong at 212-637-7028. Sincerely, Robert B. Swierupski Director, National Commodity Specialist Division