The tariff classification of a Digital Photo Frame from Hong Kong.

N010812 May 21, 2007 CLA-2-84:RR:NC:1:120 CATEGORY: Classification TARIFF NO.: 8471.70.6000 Ms. Andrea C. Pigott FedEx Trade Networks 6730 Middlebelt Road Romulus, MI 48174 RE: The tariff classification of a Digital Photo Frame from Hong Kong. Dear Ms. Pigott: In your letter dated May 3, 2007 you requested a tariff classification ruling on behalf of your client, Mark Feldstein & Associates. The submitted sample will be retained by this office. The merchandise under consideration is the Digital Photo Frame, item number 7254. It is a disk storage unit housed in a plastic frame, and is used to view stored photos. It measures approximately 2.9 inches by 1.7 inches by .7 inches at its widest points. It is permanently attached to a key ring for carrying by a 1-inch-long metal chain. The Digital Photo Frame features a 1.2 inch by 1.1 inch liquid crystal display (LCD) screen, an “on/menu” button, “up” and “down” navigational buttons, and a Universal Serial Bus (USB) “Mini-B” port. It is powered by four G13 batteries, contains 2 megabytes of internal memory, can hold up to 60 pictures, and also supports a clock/alarm feature. The Digital Photo Frame will be packaged for retail sale with a USB cable, a CD-ROM with PhotoView software, and an instruction sheet. Photos are downloaded from a personal computer or notebook to the Digital Photo Frame via the USB cable. The Digital Photo Frame is a composite good, consisting of both a key ring and a disk storage unit. However, its principal function is that of a storage unit. The Digital Photo Frame, USB cable, CD-ROM, and instruction sheet constitute a set in accordance with General Rule of Interpretation (GRI) 3(b); the Digital Photo Frame provides the essential character of this set. The Digital Photo Frame meets the requirements of a unit of heading 8471 under Note 5(C) of Chapter 84, Harmonized Tariff Schedule of the United States (HTSUS), as it is a disk storage unit connectable to the central processing unit (CPU) of an automatic data processing (ADP) machine either directly or through one or more other units, and is able to accept or deliver data in a form (codes or signals) which can be used by the system. The applicable subheading for the Digital Photo Frame, item number 7254, will be 8471.70.6000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Automatic data processing machines and units thereof…: Storage units: Other storage units: Not assembled in cabinets for placing on a table, desk, wall, floor, or similar place.” The rate of duty will be Free. Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/. 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 Denise Faingar at 646-733-3010. Sincerely, Robert B. Swierupski Director, National Commodity Specialist Division