The tariff classification of a combination recording device with flashlight and key ring from China.
Issued September 8, 2008 by U.S. Customs and Border Protection.
Tariff classification
HTS codes: 8519.81.4050
Headings: 8519
GRI rules applied: GRI 3(c)
Product description
The subject merchandise, based on the submitted information, is an oval-shaped composite article that is referred to as the “Digital Parking Reminder Keychain” (item number 466156). This small battery-operated apparatus features a recording device with record and play buttons as well as a built-in speaker and microphone. This recording device, which incorporates semiconductor media, is combined in the same plastic housing with a small LED flashlight having a push-button mechanism; furthermore, there is a metal key ring affixed to the bottom portion of the housing. It is the opinion of this office that the flashlight under heading 8513, Harmonized Tariff Schedule of the United States (HTSUS) and the recorder under heading 8519, HTS, merit equal consideration in determining the essential character of this composite article; in this regard, General Rule of Interpretation 3(c) provides that when goods cannot be classified by reference to 3(a) or 3(b), they shall be classified under the heading (in this instance heading 8519, HTS) which occurs last in numerical order among those which equally merit consideration.
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
N036249 September 8, 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 combination recording device with flashlight and key ring from China. Dear Ms. Gauthier: In your letter dated August 19, 2008, on behalf of CVS/pharmacy, you requested a tariff classification ruling. The subject merchandise, based on the submitted information, is an oval-shaped composite article that is referred to as the “Digital Parking Reminder Keychain” (item number 466156). This small battery-operated apparatus features a recording device with record and play buttons as well as a built-in speaker and microphone. This recording device, which incorporates semiconductor media, is combined in the same plastic housing with a small LED flashlight having a push-button mechanism; furthermore, there is a metal key ring affixed to the bottom portion of the housing. It is the opinion of this office that the flashlight under heading 8513, Harmonized Tariff Schedule of the United States (HTSUS) and the recorder under heading 8519, HTS, merit equal consideration in determining the essential character of this composite article; in this regard, General Rule of Interpretation 3(c) provides that when goods cannot be classified by reference to 3(a) or 3(b), they shall be classified under the heading (in this instance heading 8519, HTS) which occurs last in numerical order among those which equally merit consideration. 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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