The tariff classification of a travel smart USB car and power adapter combo from China

N041316 November 6, 2008 CLA-2-85:OT:RR:NC:N1:109 CATEGORY: Classification TARIFF NO.: 8504.40.9550 Ms. Kathy Trotta Administrative Assistant Conair Corporation 150 Milford Road East Windsor, NJ 08520 RE: The tariff classification of a travel smart USB car and power adapter combo from China Dear Ms. Trotta: In your letter dated October 7, 2008 you requested a tariff classification ruling. The merchandise subject to this ruling is a travel smart USB car and power adapter combo. The travel smart USB car and power adapter combo is identified in your letter as Model TS252AD. The TS252AD consists of AC output adapter, a DC output adapter, a USB cable, and eight different connector tips. The different connector tips enable connection to various brands of digital devices, i.e., Nokia, Motorola, Sony Ericsson, Samsung, LG, and various manufactures of GPSs. A sample of the travel smart USB car and power adapter combo was submitted for classification purposes and is being returned as per your request. The purpose of the travel smart USB car and power adapter combo is to charge and provide power to digital devices, such as mobile phones, MP3 players, MP4 players, PDAs, portable game devices, and navigational systems. The AC output adapter has an LED that lights up when plugged into a household electrical outlet (100-240VAC). The DC output adapter also has an LED that lights up when plugged into a car cigarette lighter socket (12VDC). To utilize this device one end of the USB cable is to be connected to the USB port of either the AC or DC adapter. The other end of the USB cable is to be connected appropriate connector tip for the digital device whose battery is to be charged and powered-up. The connector tip is then connected to the digital device to provide a charge and power the digital device’s battery. The travel smart USB car and power adapter combo (Model TS252AD) meets the definition of “goods put up in sets for retail sale”, without further packaging or repackaging prior to sale. First, the travel smart USB car and power adapter combo consists of at least two different articles that are, prima facie, classifiable in two different headings. Secondly, the travel smart USB car and power adapter combo is put up together to carry out the specific activity of charging and providing power to the battery of a digital device. It is our opinion that the charger imparts the essential character of the travel smart USB car and power adapter combo and, as such, is classifiable under heading 8504, as a static converter. The applicable subheading for the travel smart USB car and power adapter combo (Model TS252AD), will be 8504.40.9550, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Static Converters: Other, Rectifiers and rectifying apparatus: Other.” The rate of duty will be 1.5 percent ad valorem. 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 Linda M. Hackett at (646) 733-3015. Sincerely, Robert B. Swierupski Director National Commodity Specialist Division