The tariff classification of a radiobroadcasting car tablet entertainment system from China

N234316 November 7, 2012 CLA-2-85:OT:RR:NC:N1:108 CATEGORY: Classification TARIFF NO.: 8527.19.50 Mr. Andrew Gerard Aries Global Logistics Import Corporate Compliance 145 Hook Creek Blvd., Building A5 Valley Stream, NY 11581 RE: The tariff classification of a radiobroadcasting car tablet entertainment system from China Dear Mr. Gerard: In your letter received by this office on October 15, 2012, you requested a tariff classification ruling on behalf of your client, Innovative Technology Electronics Corporation. The merchandise in question is a radiobroadcasting car tablet entertainment system. The entertainment system is compatible with tablets and other electrical devices. This system consists of two pairs of wireless headphones with FM reception capability, an audio transmitter with USB charging port, one transformer, and one plastic tablet/headrest mount. A sample of each item was furnished and will be returned as requested. The two pairs of wireless headphones, which have built-in FM radiobroadcast reception capability, also contain an adjustable length headband, an audio-in socket that accepts a connector cable with 3.5 mm plug, a power switch, a power indicator light, a volume control, a reset button to reset the radiobroadcasting reception frequency to default, a scan button to search for the best FM frequencies, and a battery compartment for two AAA batteries, which are not included. The audio transmitter has an audio-in plug, a cigarette lighter socket power plug, a USB charging port, and four frequencies (FM 88.1 MHz, 88.7 MHz, 106.7 MHz and 107.5 MHz), which are used to transfer sound coming from a music device to the headphones via the appropriate FM channel on an automobile’s radio. The cigarette socket power plug is inserted into the in-car 12V/cigarette lighter socket to power the FM transmitter. The item has an audio-in plug that is connected to the headphones enabling the transmitter to send sound to the headphones. The USB charge port accepts a compatible size USB plug to provide power to and charge the battery of a tablet, an iPhone, a cell phone, and an MP3 player. The transformer is a Class 2 transformer with an input of 120 volts of alternating current (AC) and an output of 5 volts of direct current (DC). As such, it is a rectifier. It has a plug at one end of the electrical cord that the audio transmitter plugs into for DC power. The plastic tablet/headrest mount is used to hold a tablet in place while it is used during automobile travel. The tablet/headrest mount clips onto the back of an automobile’s front seat headrest. The mount’s opening adjusts to allow the tablet to be placed within it and the top and bottom clips to secure the tablet in place. It has a flexible goose neck to adjust the tablet mount angle within 25 degrees. Once in place, the audio transmitter/cigarette lighter power plug is inserted into the automobile’s cigarette lighter port and the audio-in plug is inserted into the tablet. The scan button on the headphone is pressed to enable it to search for the most favorable FM frequency on the automobile’s radio, one which provides the least static and clearest sound. The components are put up together to carry out a specific activity, imported ready for retail sale without repacking, and classifiable within at least two different headings. Therefore, the car tablet entertainment system qualifies as a set pursuant to General Rule of Interpretation (GRI) 3(b) which states, in part, that sets are to be classified as if they consisted of the material or component which gives them their essential character. As such in accordance with GRI 3(b), the essential character is imparted by the two pairs of wireless radio headphones. The applicable subheading for this merchandise will be 8527.19.50, Harmonized Tariff Schedule of the United States (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: Radiobroadcast receivers capable of operating without an external source of power: Other: Other. The rate of duty will be 3 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 Lisa Cariello at (646) 733-3014. Sincerely, Thomas J. Russo Director National Commodity Specialist Division