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NY N011128

May 18, 2007



TARIFF NO.: 8519.81.4050

Ms. Dana Shirl
Rhino Mounts, Inc.
150 Second Avenue North, Ste. 405
Nashville, TN 37201

RE: The tariff classification of a MP3 player from China.

Dear Ms. Shirl:

In your letter dated May 9, 2007, you requested a tariff classification ruling.

The subject merchandise, based on the submitted information, is an MP3 player with 128MB memory (flash memory, not a hard drive), which does not incorporate pre-recorded music; this device also does not contain a radio tuner.

The applicable subheading for the MP3 player will be 8519.81.4050, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Sound recording or reproducing apparatus: Other apparatus: Using magnetic, optical or semiconductor media: Other: Other. 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 Lisa Cariello at 646-733-3014.


Robert B. Swierupski

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