The tariff classification of a Car Charger for iPhone and iPod, a LiquidAUX for iPhone and iPod, a LiquidAUX Deluxe for iPhone and iPod, an Aux Cradle and a LiquidAUX Bluetooth Car Kit from China

N044299 December 10, 2008 CLA-2-85:OT:RR:E:NC:N1:109 CATEGORY: Classification TARIFF NO.: 8517.62.0050 Mr. Darren Lenox Customs Compliance Manager ACCO Brands 300 Tower Parkway Lincolnshire, IL 60069 RE: The tariff classification of a Car Charger for iPhone and iPod, a LiquidAUX for iPhone and iPod, a LiquidAUX Deluxe for iPhone and iPod, an Aux Cradle and a LiquidAUX Bluetooth Car Kit from China Dear Mr. Lenox: In your letter dated November 12, 2008, you requested a tariff classification ruling. The merchandise subject to this ruling is a Car Charger for iPhone and iPod (#33433), a LiquidAUX for iPhone and iPod (#33429), a LiquidAUX Deluxe for iPhone and iPod (#33430), an Aux Cradle (no item # yet), and a LiquidAUX Bluetooth Car Kit (#33428). All of these products are designed as interfaces to connect various music devices (i.e., iPhones, iPods, and music phones) to a car’s built-in stereo auxiliary (“aux”) port. These standard 3.5mm aux audio ports are now being factory installed in many makes and models of automobiles, and will likely become standard features in the near future. The aux ports are primarily used to connect various music devices for playing through the car’s stereo. The above aux port products perform direct point-to-point reception and transmission functions while using a wired data connection, instead of radio frequency signals. These products interface with an iPhone or iPod via a 30-pin dock or 30-pin cable connection (specific only to Apple devices); or with other cellular music phones via Bluetooth. The interfacing apparatus contains printed circuit board assemblies with microcontrollers and authentication chips that receive the digital music signals from the iPod or other device. These communication components are housed in the cigarette lighter charger portion of the apparatus. The apparatus then configures and processes the data into the necessary analog signals, and transmits to the car stereo’s 3.5mm aux port. Submitted with this ruling are example Product Engineering Specifications of this communication functionality. The first item subject to this ruling is the Car Charger Deluxe for iPhone and iPod (#33433). The apparatus creates a wired connection between the user’s iPod or iPhone device and the car’s aux port for the communication (receiving/transmitting) of music signals in order to listen to music through the car stereo, while charging the device at the same time. It contains a 30-pin dock and cradle for connecting the device, which is mounted on a charger for the car’s cigarette lighter. The charger housing contains the reception and transmission components. An auxiliary-in cable is then connected to the apparatus underneath the charger and to the car’s stereo aux port. The primary selling feature of this product is the wired connection to the aux port for playing music through the car’s stereo. The second item subject to this ruling is the LiquidAUX for iPhone and iPod (#33429). This apparatus creates a wired connection with a car’s stereo aux port, while charging it at the same time. This product does not contain a dock/cradle for connecting their device. Instead, a 30-pin connector cable connects the device with the charger housing which then connects to the car’s stereo aux port. The charger housing contains the reception and transmission components. In addition, the apparatus includes a wireless remote control attachable to the steering wheel as an add-in convenience for playing, pausing and skipping music on the connected device without having to reach to handle device itself. The primary selling feature of this product is the wired connection to the aux port. The third item subject to this ruling is the LiquidAUX Deluxe for iPhone and iPod (#33430). This apparatus is virtually identical to item #33429, except that it includes a 30-pin dock and cradle mounted to the charger instead of a mere cable connection. The wired connection to the aux port also imparts the selling feature of this product. The fourth item subject to this ruling is the Aux Cradle (no item # yet assigned). This product, while still in development, is different from the previous apparatus. It is comprised of various 30-pin connectors based on the type of iPhone or iPod device. The device and connector are then connected to a plastic dock which plugs into the car’s stereo aux port. Communication components in this product are housed in the connector, rather than the cigarette lighter charger like the other listed products. This wired connection is the only function of this product. The fifth item subject to this ruling is the LiquidAUX Bluetooth Car Kit (#33428). This apparatus is very similar to item #33429, except that the charger housing contains a wireless Bluetooth technology for communicating with cellular music phones instead of iPhones or iPods. Like #33429, there is a wired connection from the charger housing to the car’s stereo aux port. The primary selling features of this product are the wireless Bluetooth communication with the music device and wired connection to the aux port. It is the opinion of this office that the reception and transmission function imparts the essential character of the Car Charger Deluxe for iPhone and iPod (#33433), LiquidAUX for iPhone and iPod (33429), LiquidAUX Deluxe for iPhone and iPod (#33430) and LiquidAUX Bluetooth Car Kit (#33428). The Aux Cradle (no item # yet), which does not contain a charging unit, is a reception/transmission device. As such, all five devices are classifiable under heading 8517, as reception and transmission apparatus. The applicable subheading for the Car Charger Deluxe for iPhone and iPod (#33433), LiquidAUX for iPhone and iPod (#33429), LiquidAUX Deluxe for iPhone and iPod (#33430), LiquidAUX Bluetooth Car Kit (#33428) and the Aux Cradle (no item # yet) will be 8517.62.0050, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Machines for the reception, conversion and transmission or regeneration of voice, images or other data, including switching and routing apparatus: 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 Linda M. Hackett at 646-733-3015. Sincerely, Robert B. Swierupski Director National Commodity Specialist Division