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NY C82013

December 15, 1997

CLA-2-85:RR:NC:1:108 C82013


TARIFF NO.: 8525.10.3040

Mr. William R. Palle
Customs Compliance Manager
Matsushita Logistics Company
Two Panasonic Way
Secaucus, NJ 07094

RE: The tariff classification of Model No. ENG56419G RF Front-End System.

Dear Mr. Palle:

In your letter dated November 18, 1997, you requested a tariff classification ruling. A sample was submitted.

The ENG56419G RF Front-End System is a compact composite unit combining the three functions of an electronic tuner, VIF, and RF converter. The three functions are mounted together in a common housing for installation in a video tape recorder (VTR). The electronic tuner selects desired signals from VHF to UHF, amplifies, and converts to intermediate frequencies. The VIF unit is the intermediate frequency signal processor, converting the information of intermediate frequency carriers into video and sound base band. The RF converter modulates the video and sound signals into the receiving channel of the television receiver, and also incorporates an RF switch that electronically distributes television signals from the antenna to the VTR transmitting the RF signal from the VTR to the television receiver. When installed in the VTR, the product provides the option of direct viewing from a television broadcast receiver while simultaneously recording a program on the VTR.

You state in your letter that, of the three functions performed by the ENG56419G, the RF converter is essential to the overall operation of the unit. We agree that the principal function resides in the RF converter, since the tuner and VIF units would not be operable in the absence of the signals transmitted by the RF converter.

The applicable subheading for the ENG56419G RF Front-End System will be 8525.10.3040, Harmonized Tariff Schedule of the United States (HTS), which provides for "[t]ranmission apparatus for radiotelephony, radiotelegraphy, radiobroadcasting or television, whether or not incorporating reception apparatus or sound recording or reproducing apparatus...[t]ransmission apparatus: [t]elevision: [o]ther...[o]ther: [o]ther." The general rate of duty will be 2.6 percent ad valorem in 1997. The scheduled general rate of duty for 1998 is 2.2 percent ad valorem.

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 Harvey Kuperstein at 212-466-5672.


Robert B. Swierupski

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