N035111 N0 Ruling Active

The tariff classification of a voice-recording photo frame with built-in clock from China.

Issued August 19, 2008 by U.S. Customs and Border Protection.

Tariff classification

HTS codes: 8519.81.4050

Headings: 8519

Product description

The subject merchandise, based on the submitted sample, is an oblong-shaped battery-operated voice-recording photo frame, item number 466153, which measures approximately 7 ½ inches by 6 inches and incorporates semiconductor media. The plastic frame, which is designed to accommodate the insertion of a 4-inch by 6-inch photo, has record and play buttons as well as a built-in speaker; furthermore, this frame has a built-in stand and a digital LCD clock with date, time and alarm modes in noting the alarm will be the stored voice message. This merchandise, being composed of a digital voice-recording device incorporated with a photo frame having a built-in digital clock, is considered to be a composite good for tariff classification purposes with the essential character being imparted by the recording device.

CBP rationale

The applicable subheading for this merchandise will be 8519.81.4050, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Sound recording or reproducing apparatus: Other apparatus: Using magnetic, optical or semiconductor media: Other: Other.

Full text

N035111 August 19, 2008 CLA-2-85:OT:RR:NC:1:108 CATEGORY: Classification TARIFF NO.: 8519.81.4050 Ms. Una Gauthier CVS Onsite Import Client Liaison Barthco International, Inc. (Division of Ozburn-Hessey Logistics) One CVS Drive Woonsocket, RI 02895 RE: The tariff classification of a voice-recording photo frame with built-in clock from China. Dear Ms. Gauthier: In your letter dated July 30, 2008, on behalf of CVS/pharmacy, you requested a tariff classification ruling. The subject merchandise, based on the submitted sample, is an oblong-shaped battery-operated voice-recording photo frame, item number 466153, which measures approximately 7 ½ inches by 6 inches and incorporates semiconductor media. The plastic frame, which is designed to accommodate the insertion of a 4-inch by 6-inch photo, has record and play buttons as well as a built-in speaker; furthermore, this frame has a built-in stand and a digital LCD clock with date, time and alarm modes in noting the alarm will be the stored voice message. This merchandise, being composed of a digital voice-recording device incorporated with a photo frame having a built-in digital clock, is considered to be a composite good for tariff classification purposes with the essential character being imparted by the recording device. The applicable subheading for this merchandise will be 8519.81.4050, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Sound recording or reproducing apparatus: Other apparatus: Using magnetic, optical or semiconductor media: Other: Other. 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 Lisa Cariello at (646) 733-3014. Sincerely, Robert B. Swierupski Director National Commodity Specialist Division

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