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NY M80302

February 23, 2006

CLA-2-85: RR: NC: 1:108 M80302


TARIFF NO.: 8527.31.6040

Mr. Winston Symonds
Sony Electronics, Inc.
16530 Via Esprillo
San Diego, California 92127

RE: The tariff classification of a home entertainment center from Mexico.

Dear Mr. Symonds:

In your letter dated February 1, 2006 you requested a tariff classification ruling.

The item in question is a home entertainment center denoted as model number NHS-1010. It consists of a radiobroadcast receiver/amplifier unit, a CD player, a 400-disc DVD player, a DVD/VCR combo player/recorder and a remote control. All of the individual components are combined in a single unit and designed to function as an integrated unit. Each individual component is directly connected to a single panel connection within the housing. This connection effectively merges the individual components into a single integrated home entertainment center. This design enables builders to custom integrate such a unit in a newly built home.

It should be noted that this particular model neither incorporates a television nor a video monitor. The ultimate purchaser can adapt any such device at a later date.

Legal Note 3 to Section XVI states and requires “That unless the context otherwise requires, composite machines consisting of two or more machines fitted together to form a whole and other machines designed for the purpose of performing two or more complementary functions alternative functions are to be classified as if consisting only of that component or as being that machine which performs the principal function”. This office considers the home entertainment center; model NHS-1010, to be a composite machine in accordance with Section XVI Note 3. It consists or two or more machines fitted together in a whole unit and together they provide both audio and video entertainment.

It is the opinion of this office that no single component provides a principal function. The capability of each component varies and the choice of either audio or video entertainment is at the discretion of the user. Therefore classification will be in accordance with GRI 3c. GRI 3c requires classification to be under the provision that appears last in numerical order of the tariff.

The applicable subheading for the home entertainment center, model NHS-1010 will be 8527.31.6040, Harmonized Tariff Schedule of the United States (HTSUS), 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: Combined with sound recording or reproducing apparatus: Other: Other Incorporating optical disc (including compact disc) players or recorders. The rate of duty will be free.

Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.

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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