The tariff classification of karaoke systems from China.

NY L85084 June 10, 2005 CLA-2-85: RR: NC: 1:108 L85084 CATEGORY: Classification TARIFF NO.: 8519.99.00 Mr. Joseph Hoffacker Barthco Trade Consultants The Navy Yard 5101 S. Broad Street Philadelphia, PA 19112-1404 RE: The tariff classification of karaoke systems from China. Dear Mr. Hoffacker: In your letter dated May 27, 2005, on behalf of The Singing Machine Company, you requested a tariff classification ruling. The items in question are karaoke systems denoted as models STVG-998 and STVG-999. Each system is a pedestal karaoke machine, combined in the same housing with a video camera, a 7” black and white monitor and AM/FM radio and a built-in wireless microphone. The models only differ in that model STVG-998 has built-in speakers and model STVG-999 has attached tower speakers. The monitor is used for the visual display of song lyrics and it is important to note that neither model has sound recording capability. Headquarters ruling 966608 provides guidance in this matter. Legal Note 3 to Section XVI sates and requires “That unless the context otherwise requires, composite machines consisting of two or more machines fitted together to form a whole and other machines designed for the purpose of performing two or more complementary functions or alternative functions are to be classified as if consisting only of that component or as being that machine which performs the principal function”. This office considers each specified model to be a composite machine in accordance with Legal note 3 to Section XVI. It is the opinion of this office that the principal function, for each specified karaoke system, is as a sound reproduction device. The reason one would use these devices is to reproduce sounds to sing along to. Any other functions, provided by the other incorporated devices, are ancillary to the main function of an individual singing along to the reproduced music. The applicable subheading for the above specified karaoke systems will be 8519.99.00, Harmonized Tariff Schedule of the United States (HTS), which provides for Turntables, record players, cassette players and other sound reproducing apparatus, not incorporating a sound recording device: Other sound reproducing apparatus: Other. The rate of duty will be free. 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 Michael Contino at 646-733-3014. Sincerely, Robert B. Swierupski Director, National Commodity Specialist Division