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NY K86228

May 28, 2004
CLA-2-85:RR:NC:1:108 K86228


TARIFF NO.: 8520.90.0080

Mr. Charles S. Parisi
Parisi Services, Inc.
Customs Brokerage and Freight Forwarding
P.O. Box 91217
Los Angeles, CA 90009

RE: The tariff classification of a recording device with photo frame from China.

Dear Mr. Parisi:

In your letter dated May 13, 2004, you requested a tariff classification ruling.

The submitted sample is referred to as the “Memories Forever Recordable Talking Ornament.” It consists of a battery-operated sphere-shaped audio recording device, measuring approximately 2 ½ inches in diameter, with a voice recording capability to record vocal messages up to 15 seconds per message. This device incorporates a microphone, a top button for playing and recording, and a bottom play/record/off switch. It also has a built-in photo frame that is accessed by removing the article’s top cap securing the two hemispheres of this article.

This merchandise, being composed of a recording device and photo frame, is considered to be a composite good with the essential character being imparted by the recording device.

The applicable subheading for the recording device with photo frame will be 8520.90.0080, Harmonized Tariff Schedule of the United States (HTS), which provides for Magnetic tape recorders and other sound recording apparatus, whether or not incorporating a sound reproducing device: Other, Other. The rate of duty will be free.

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 646-733-3014.


Robert B. Swierupski

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