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NY N007369

March 12, 2007



TARIFF NO.: 8543.70.9650

Ron Reuben
Regulatory and Compliance Consultant
4000 Redondo Beach Avenue Ste 103
Redondo Beach, CA 90278

RE: The tariff classification of four programmable remote control units from unspecified country.

Dear Mr. Reuben:

In your letter dated February 14, 2007, you requested a tariff classification ruling on behalf of Universal Electronics, Inc.

The first item concerned is the Atlas DVR/PVR 5-device programmable infrared remote control (Model # 1055-xxxx-0001). This remote allows the user to consolidate up to five “original” home entertainment remote controls into one universal remote. This remote works solely by infrared technology.

The second item concerned is the MediaRemote with SimpleCenter (Model # URC-3010RAO). This remote is a programmable, infrared and radio frequency (R.F.) remote control unit. The MediaRemote with SimpleCenter allows the user to control digital media and access it on a Personal Computer or any entertainment device connected to a Personal Computer, by using the “SimpleCenter” PC software and the USB R.F. receiver (Model # 38KL). The USB R.F. receiver may or may not be imported with the MediaRemote. The MediaRemote also serves as a “Universal Remote” that can be programmed to control a variety of traditional home entertainment equipment using either infrared technology or radio frequency technology.

The third item concerned is the StarChoice programmable remote control (Model # URC 551). The StarChoice remote control allows the user to consolidate up to five “original” home entertainment remote controls into one universal remote. This remote operates on both infrared and radio frequency technology, allowing the user to control virtually any type of home entertainment device.

The forth item concerned is the HTPRO - Plus. The HTPRO – Plus consists of a programmable remote control (Model # URC 9811B00) and a relay unit (Part # CCHAB01). The remote control uses both infrared and radio frequency (R.F.) technologies. The programmable remote uses its infrared technology to control a variety of home entertainment equipment and it’s R.F. technology to control the relay unit. In order to control a device via infrared technology you must have a clear line of sight between the remote and the device being controlled. When using R.F. technology you do not need a clear line of sight, R.F. transmits a great distance, even through walls and floors. By using the remote’s R.F. technology in conjunction with the relay, you can control a device, that uses infrared technology, from a location that is out of the line of sight. The relay, which uses infrared technology to control the particular home entertainment equipment, would need to be located within a clear line of sight of the device being controlled. Once the relay receives the R.F. signal from the remote it converts that signal to infrared and directs it toward the device being controlled. Ultimately it is the infrared signal that is controlling the intended device.

The applicable subheading for the Atlas DVR/PVR 5-device infrared remote controller (Model # 1055-xxxx-0001), the MediaRemote with SimpleCenter (Model # URC-3010RAO) with or without the R.F. receiver (Model # 38KL), the StarChoice remote control (Model # URC 551), and the HTPRO – Plus remote control (Model # URC 9811B00) with relay unit (Part # CCHAB01) will be 8543.70.9650, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electrical machines and apparatus.: Other machines and apparatus: Other: Other: Other: Other”. The rate of duty will be 2.6%.

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 Steve Pollichino at 646-733-3008.


Robert B. Swierupski

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