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September 8, 1999

CLA-2-85: RR:NC:1:108 E86072


TARIFF NO.: 8527.32.5010

Mr. Dennis Heck
Yamaha Corporation of America
6600 Orangethorpe Avenue
P.O. Box 6600
Buena park, CA 90622-6600

RE: The tariff classification of a stereo component system from Malaysia.

Dear Mr. Heck:

In your letter dated August 26, 1999 you requested a tariff classification ruling.

The item in question is denoted as the Yamaha CRX-E100 Micro Component System. This system is composed of two separate sub-components, which can be either stack mounted or used side by side.

The specific components are the RX-E100 Tuner/Amplifier Unit and the CDX-E100 Compact Disk (CD) Unit. The RX-E100 Tuner Amplifier Unit consists of an AM/FM tuner and amplifier with a sleep clock/timer, in a single housing, and an infrared remote control device. The CDX-E100 CD Unit is a standard CD player with random and program play without any recording capability. These components will be repackaged, after importation, in the United States with speakers, and then sold at the retail level. The two components can only operate with a 110-volt external power source. The components utilize standard RCA pin jacks/ cables for connection to each other and these cable connections are necessary for the operation of the CD player in conjunction with the AM/FM tuner.

According to the information provided, the components cannot be purchased separately but rather as a complete package only after the incorporation of the speakers is complete and offered for retail sale.

Based upon HQ Rulings 958914 and 958577 this component system is neither a set nor a functional unit. The tuner and CD player are repackaged after importation thus not meeting the third criterion for “goods put up in sets for retail sale”. Also since the stereo system is imported without speakers it is considered incomplete and therefore cannot be considered an incomplete functional unit.

The item in question however is considered a composite good. The subject stereo system is composed of separable components, which are adapted to each other through the RCA cable connections and are complementary to each other and together form a whole, which is not offered for sale as separate components. The RCA cable connections are necessary for the proper function of the components. Therefore based upon these factors the stereo system, in its imported condition, is a composite good under the application of GRI 3(b).

The Yamaha CRX-E100 Micro Component System, consisting of 2 separate components, is a composite good. The essential character is imparted by the RX-E100 Tuner/Amplifier, which incorporates a digital clock and is valued over $40.

The applicable subheading for the CRX-E100 Micro Component System will be 8527.32.5010, Harmonized Tariff Schedule of the United States (HTS), which provides for Reception apparatus for radiotelephony, radiotelegraphy or radiobroadcasting, whether or not combined, in the same housing, with sound recording or reproducing apparatus or a clock: Other radiobroadcast receivers, including apparatus capable of receiving also radiotelephony or radiotelegraphy: Not combined with sound recording or reproducing apparatus but combined with a clock: Other incorporating a digital clock or clock timer. The rate of duty will be 3 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 Michael Contino at 212-637-7039.


Robert B. Swierupski

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