The tariff classification of surround sound speaker system from China

N119942 August 27, 2010 CLA-2-85:OT:RR:NC:N1:109 CATEGORY: Classification TARIFF NO.: 8518.29.8000 Mr. Eddie Fung AMR Import Export Administrator Logitech, Inc 6505 Kaiser Drive Fremont, CA 94555 RE: The tariff classification of surround sound speaker system from China Dear Mr. Fung: In your letter dated August 19, 2010 you requested a tariff classification ruling. The merchandise subject to this ruling is a surround sound speaker system. It is referred to in your letter as Surround Sound Speakers Z506 (Logitech Part# 980-000430). The Surround Sound Speakers Z506 consist of one center speaker with two active drivers, one front left satellite speaker with 1 active driver, one front right satellite speaker with 1 active driver, one rear left satellite speaker with 1 active driver, one rear right satellite speaker with 1 active driver, and one sub-woofer with 1 active driver. The system will use 3.5mm input cables to connect to 6-channel audio sources. It has an auxiliary RCA jack to allow users to connect it to all their audio sources. The speaker system also allows stereo content to be distributed to all 6 channels through matrix signal processing. The Surround Sound Speaker Z506 system will be imported as a retail set ready for retail sale. You suggested Harmonized Tariff Schedule of the United States (HTSUS) subheading 8518.22.0000, which provides for “Multiple loudspeakers, mounted in the same enclosure surround sound speaker system (Surround Sound Speakers Z506 (Logitech Part# 980-000430)). However, the surround sound speaker system consists of four single loudspeakers each mounted in their enclosure, one sub-woofer mounted in its enclosure, and one loudspeaker containing two loudspeakers mounted in the same enclosure. As such, the surround sound speaker system consists of more than simply multiple loudspeakers mounted in the same enclosure. It also consists of five single loudspeakers, one being a sub-woofer, each mounted in their own enclosure. The surround sound speaker system is more specifically provided for in subheading 8518.29.8000, as loudspeakers, consisting of a combination of single loudspeakers and multiple loudspeakers, other than merely single loudspeakers or merely multiple loudspeakers. Therefore, subheading 8518.22.0000 is inapplicable. The applicable subheading for the surround sound speakers (Surround Sound Speakers Z506 (Logitech Part# 980-000430)) will be 8518.29.8000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Loudspeakers, whether or not mounted in their enclosures: Other: Other.” The rate of duty will be 4.9 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