The tariff classification of a recording photo frame from China.

N030942 June 26, 2008 CLA-2-85:OT:RR:NC:1:108 CATEGORY: Classification TARIFF NO.: 8519.81.4050 Ms. Sidestra Elvi Liss Global, Inc. 7746 Dungan Road Philadelphia, PA 19111 RE: The tariff classification of a recording photo frame from China. Dear Ms. Elvi: In your letter dated June 12, 2008, you requested a tariff classification ruling. Sample is being returned as requested. The submitted sample is a battery-operated globe-shaped voice-recording photo frame, which is referred to as the “Talking Photo Ornament” (item number 9002869). This device, which incorporates semiconductor media, has a built-in microphone and speaker, as well as a slide switch for recording and playing a personalized message for a maximum time of 15 seconds. It has a built-in small circular photo frame that is accessed by turning its top cap, which secures the two hemispheres of this article; there is also a top ribbon-like loop for hanging. This merchandise, being composed of a voice-recording device incorporated with a photo frame, is considered to be a composite good for tariff classification purposes with the essential character being imparted by the recording device. The applicable subheading for this recording photo frame will be 8519.81.4050, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Sound recording or reproducing apparatus: Other apparatus: Using magnetic, optical or semiconductor media: Other: 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 Lisa Cariello at 646-733-3014. Sincerely, Robert B. Swierupski Director, National Commodity Specialist Division