The tariff classification of an electronic reading device from China

N107875 June 16, 2010 CLA-2-85:OT:RR:NC:N1:112 CATEGORY: Classification TARIFF NO.: 8543.70.9650, 9817.00.94 Michael Skidmore Compliance Manager Dynasty International, Inc. 365 Chelsea St. East Boston, MA 02128 RE: The tariff classification of an electronic reading device from China Dear Mr. Skidmore: In your letter dated May 24, 2010, you requested a tariff classification ruling on behalf of your client Optelec US, Inc. The item concerned is referred to as the ClearReader Plus. It is described as an intuitive electronic reading device specifically designed for use by the legally blind or persons with very poor eyesight. It is used to scan/capture printed material such a letters, newspapers or books and convert the printed text into an audible natural sounding voice. This device incorporates, a high resolution camera which is built into a swing-out camera arm, an object light, built-in stereo speakers, an Intel atom processor, a control panel, an integrated battery and a foldable carrying handle. The ClearReader Plus, which is packaged ready for retail sale, will include a power adaptor, power cord, and a user manual. In use, the swing out camera arm would be pulled out, into the appropriate position. Then the text that is to be read is placed underneath the camera. The user presses the scan button, and the camera takes a snap shot of the printed page. The scanned image is interpreted by the optical character recognition software which converts the printed text into an audible synthetic voice that is then played over the speaker system. The user has the choice of four pre-stored languages. The ClearReader cannot store text beyond the initial snapshot. Once the object being read is removed and a new object is in place the previous image is lost. This device can be used to read text, tables and spreadsheets. The applicable subheading for the ClearReader Plus will be 8543.70.9650, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electrical machine…: Other machines and apparatus: Other: Other: Other: Other.” The rate of duty will be 2.6%. You propose a secondary classification in HTSUS 9817.00.96, citing New York Ruling Letter N080114, which is dated November 9, 2009. However, while this item is likewise clearly designed to benefit those whose vision cannot be corrected for reading via contact lenses or eyeglasses, it includes benefiting the totally blind since it is speaking the text, not magnifying it. Headquarters Ruling Letter 952398 MBR, December 30, 1992, changed the classification of a Talking Book Cassette Player from 9817.0096 (as had been ruled in HRL 088629 NLP, May 22, 1991) to 9817.00.94. As such the proper secondary classification of the ClearReader Plus, would be 9817.00.94. 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 Steven Pollichino at (646) 733-3008. Sincerely, Robert B. Swierupski Director National Commodity Specialist Division