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NY 814281

September 5, 1995

CLA-2-84:S:N:N1:110 814281


TARIFF NO.: 8520.90.0080

Mr. James B. Silliman
Fritz Companies, Inc.
3850 Nome Street, Unit J
Denver, Colorado 80239

RE: The tariff classification of a recording calculator from China.

Dear Mr. Silliman:

In your letter dated August 25, 1995, on behalf of Command Communications Inc., you requested a tariff classification ruling.

The merchandise under consideration involves a model MC-20 recording calculator. This device is a pocket calculator with an integrated digital recorder. It can be used as a full function calculator as well as a personal voice messaging recorder.

The MC-20 recording calculator has the combined function of a calculator and a memo recording playback device. The calculator function allows for addition, subtraction, division multiplication, percentage, and memory sum, subtraction and recall. The recording playback function has recording and playback functions with a maximum of 20 seconds worth of multiple messages. This is total time, not time per message.

The MC-20 recording calculator is a composite machine, since it incorporates both calculating and recording components. This device appears to be equally used both as a recorder and a calculator. In this case the item's essential character cannot be determined as resulting from either function. Therefore, GRI-3(c), the classification occurring last in numerical order appears to be applicable.

The applicable subheading for the MC-20 recording calculator will be 8520.90.0080, Harmonized Tariff Schedule of the United States (HTS), which provides for other, other sound recording apparatus. The rate of duty will be 3.1 percent ad valorem.

This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177).

A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction.


Jean F. Maguire
Area Director

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