The tariff classification of a multi-card reader/writer with built in USB hub from China.

N073716 September 25, 2009 CLA-2-84:OT:RR:E:NC:1:120 CATEGORY: Classification TARIFF NO.: 8471.70.9000 Ms. Charlotte J. Chowning Jasco Products Company, LLC 10 E. Memorial Road Oklahoma City, OK 73114 RE: The tariff classification of a multi-card reader/writer with built in USB hub from China. Dear Ms. Chowning: In your letter dated August 26, 2009 you requested a tariff classification ruling. The merchandise under consideration is described as the All-in-One Reader with 3 Port Hub, item number 97962. You state that it consists of a plastic housing measuring approximately 3 inches wide by 3 inches high by ½ inch deep. The All-in-One Reader features 4 card slots that can accommodate 19 different card types, including Compact Flash, MicroDrive, Secure Digital, MultiMedia, SmartMedia, xD-Picture, and Memory Stick cards. The All-in-One Reader does not contain its own memory, but simply serves as a drive unit to read and write data to and from flash memory media. An integrated USB (universal serial bus) mini connector allows the reader to be connected to the USB port of an automatic data processing (ADP) machine via an included USB cable. The All-in-One Reader features a built-in 3-port USB hub, which adds 3 USB 2.0 ports to connect peripherals to the computer through the reader/writer. The All-in-One Reader with 3 Port Hub is a composite machine, the essential character of which is the storage device. It is a storage unit in the form of a drive for media that meets the requirements of Note 5(C) to Chapter 84, HTSUS. It is connectable to the central processing unit of an ADP machine directly or through one or more other units; and it is able to accept or deliver data in a form which can be used by the system. The All-in-One Reader is packaged together with a six foot USB 2.0 mini device cable, a CD with driver software and instructions, and an AC power adapter, and meets the definition of “goods put up in sets for retail sale.” As per GRI 3(b), classification is determined by the component, or components taken together, which confer on the set as a whole its essential character. The All-in-One Reader clearly provides the essential character of the set. The applicable subheading for the All-in-One Reader with 3 Port Hub will be 8471.70.9000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Automatic data processing machines and units thereof…: Storage units: Other storage units: 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 Denise Faingar at (646) 733-3010. Sincerely, Robert B. Swierupski Director National Commodity Specialist Division