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HQ 083065

August 29, 1989

CLA-2 CO:R:C:G 083065 TLS


TARIFF NO.: 8527.31.4000

Ms. Donna Shira
Sharretts, Paley, Carter & Blauvelt, P.C. 80 Broad Street
New York, New York 10004

RE: Classification of stereo component system

Dear Ms. Shira:

You request a ruling on the proper classification of a stereo component system under the Harmonized Tariff Schedule of the United States Annotated (HTSUSA). Your letter dated September 8, 1988 has been referred to our office for this purpose.


The inquirer represents a company that wishes to import a stereo system consisting of different components packaged and marketed together as one unit. The system includes an amplifier/tuner with a built-in graphic equalizer, a cassette recorder/player, a cassette player, a semi-automatic turntable, two stereo speakers, and a component rack. The cassette player is incapable of recording sound, as opposed to the recorder/player, which records as well as plays back sound.


Is the stereo system properly classifiable under heading 8527, HTSUSA, which covers reception apparatus for radiotelephony, radiotelegraphy or radiobroadcasting, whether or not combined, in the same housing, with sound recording or reproducing apparatus or a clock.


The General Rules of Interpretation (GRI) govern the classification of articles under the HTS. GRI 1 requires that classification be determined according to the terms of the
headings and any relative section or chapter notes. The stereo system is marketed and sold as an item for receiving radio broadcasts, as well as for reproducing of sound, specifically music in various forms. The separate components reproduce sound from different media, including cassette tapes, records, and AM/FM radio. The common thread between these components is the fact that the entire system is integrated with the purpose of reproducing musical sound in stereo. The amplifier/tuner is the component that is essential to that purpose. Its main function is to actually receive the radio broadcasts. None of the other components is functional without the use of the amplifier. This includes the cassette player, which as noted before, cannot record sound.

Heading 8527 covers reception apparatus for radiobroadcasting, whether or not combined with sound recording or reproducing apparatus. The stereo system receives radio broadcasts through the tuner and is equipped with a cassette recorder/player for sound recording. The system is also equipped with a turntable, a cassette player, and two stereo speakers for additional sound reproduction. Inasmuch as the amplifier/tuner is the main component in this system, it constitutes the principal character of this product. The other components enhance the versatility and, perhaps, the quality of the system but can be replaced or done without altogether. The stereo system would still be capable of performing its radio broadcast receiving functions. The system is properly classifiable under heading 8527.


The stereo system is classified under subheading 8527.31.4000, HTSUSA, as a reception apparatus for radiobroadcasting or radiotelephony incorporating a tape player which is incapable of recording.


John Durant, Director

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