The tariff classification of a digital photo frame key ring from an unspecified country.

N035240 August 15, 2008 CLA-2-84:OT:RR:E:NC:1:120 CATEGORY: Classification TARIFF NO.: 8471.70.6000 Ms. Corinne K. Coffey Fujifilm Holdings America Corporation 200 Summit Lake Drive 4th Floor Valhalla, NY 10595 RE: The tariff classification of a digital photo frame key ring from an unspecified country. Dear Ms. Coffey: In your letter dated August 7, 2008 you requested a tariff classification ruling. The merchandise under consideration is the Digital Keychain 1.1” LCD, model number 1-1DPF100. It is a storage unit housed in an oval-shaped plastic frame permanently attached to a metal key ring, and is used to view stored photos. Photos are downloaded from an automatic data processing (ADP) machine, such as a personal computer, to the Digital Keychain via a universal serial bus (USB) cable. The Digital Keychain features an LCD (liquid crystal display) screen for viewing the stored photos, a “power on-off” button, “previous” and “next” buttons, and a USB “Mini-B” port. It is powered by an internal rechargeable battery and, according to the manufacturer’s website (www.pcgearhead.com), is capable of storing up to 56 photos in JPG and BMP formats. The Digital Keychain 1.1” LCD is a composite good, consisting of both a key ring and a storage unit. However, its principal function is that of a storage unit. The applicable subheading for the Digital Keychain 1.1” LCD, model number 1-1DPF100, will be 8471.70.6000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Automatic data processing machines and units thereof…: 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