The tariff classification of Bluetooth speakers with radiobroadcast receivers from China

N312832 July 15, 2020 CLA-2-85:OT:RR:NC:N2:208 CATEGORY: Classification TARIFF NO.: 8527.91.6040; 9903.88.15 Steven Cohen American Signature Inc. 4300 E. 5th Ave Columbus, OH 43219 RE: The tariff classification of Bluetooth speakers with radiobroadcast receivers from China Dear Mr. Cohen: In your letter dated June 9, 2020, you requested a tariff classification ruling. The first item under consideration is referred to as the “X Tiger,” which measures 19.8"L X 17.3"W X 49.8"H. The X Tiger consists of an FM tuner with auto scan and a built-in DVD/CD Player, two 15-inch woofer speakers, and two tweeters enclosed in a wood shell with reinforced steel corners. This radiobroadcast receiver incorporating sound recording or reproducing apparatus has Bluetooth capability and can reproduce sound from an SD card or a USB memory device. You have proposed classification of the X TIGER under subheading 8518.22.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Multiple loudspeakers, mounted in the same Enclosure”. Based upon the information submitted this audio system is not solely a speaker assembly. This unit incorporates other audio components that allow for the reproduction of sound, i.e. DVD player/CD player, USB port, SD card reader, FM receiver, etc. The inclusion and additional functionality of the various sound reproduction components would take this device beyond the intended scope of heading 8518, HTSUS. CBP has consistently classified audio systems that incorporate sound reproducing and radio reception components outside of heading 8518, HTSUS. Based on the facts presented and past precedence, heading 8518, HTSUS, would be inapplicable. The second item under consideration is referred to as the “X Force,” which measures 15.25" L X 52.25" W X 23.25"H. The X Force is a radiobroadcast receiver with three 15-inch woofers, a subwoofer, two tweeters, and a built-in DVD/CD player enclosed in a wood frame with reinforced steel corners. This radio contains an FM tuner with auto scan, Bluetooth capability, and can reproduce sound from a USB memory device, an SD card, and the built-in DVD/CD player. The applicable subheading for the X Tiger and the X Force will be 8527.91.6040, HTSUS, which provides for Reception apparatus for radiobroadcasting, whether or not combined, in the same housing, with sound recording or reproducing apparatus or a clock: Other: Combined with sound recording or reproducing apparatus: Other: Other: Incorporating optical disc (including compact disc) players or recorders. The rate of duty will be Free. Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 8527.91.6040, HTSUS, unless specifically excluded, are subject to an additional 7.5 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.15, in addition to subheading 8527.91.6040, HTSUS, listed above. The HTSUS is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, you may refer to the relevant parts of the USTR and CBP websites, which are available at https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and https://www.cbp.gov/trade/remedies/301-certain-products-china respectively. 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 the World Wide Web at https://hts.usitc.gov/current. 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 [email protected]. Sincerely, Steven A. Mack Director National Commodity Specialist Division