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NY N013297

July 11, 2007



TARIFF NO.: 8471.70.6000

Ms. Peggy Compton
Electro Brand, Inc.
1127 S. Mannheim Road, Suite 305
Westchester, IL 60154

RE: The tariff classification of a Digital Photo Frame key ring from China.

Dear Ms. Compton:

In your letter dated June 18, 2007, you requested a tariff classification ruling. The submitted sample will be returned to you.

The merchandise under consideration is the Digital Photo Frame key ring, model number 1103MO. It is a disk storage unit housed in a plastic heart-shaped frame attached to a key ring, and is used to view stored photos. Photos are downloaded from an automatic data processing (ADP) machine, such as a personal computer or notebook, to the Digital Photo Frame via a Universal Serial Bus (USB) cable. The housing of the Digital Photo Frame measures approximately 2 inches by 2 inches by .8 inches at its widest points, and is permanently attached to a circular metal key ring for carrying by a 1.6 inch long cord. The Digital Photo Frame features a .8 inch by .6 inch liquid crystal display (LCD) screen, an “on” button, “forward” and “back” navigation buttons, a “delete” button, and a USB “Mini-B” port. It is powered by a rechargeable lithium battery, contains 8 Megabytes (MB) of Flash memory, and can hold up to 72 digital images. The Digital Photo Frame is packaged for retail sale in a plastic clamshell case with a USB cable, a CD-ROM with setup software, and an instruction sheet.

The Digital Photo Frame is a composite good, consisting of both a key ring and a disk storage unit. However, its principal function is that of a storage unit. The Digital Photo Frame, USB cable, CD-ROM and instruction sheet constitute a set in accordance with General Rule of Interpretation (GRI) 3(b); the Digital Photo Frame provides the essential character of the set.

The Digital Photo Frame meets the requirements of a unit of heading 8471 under Note 5(C) of Chapter 84, Harmonized Tariff Schedule of the United States (HTSUS), as it is a disk storage unit connectable to the central processing unit (CPU) of an ADP machine either directly or through one or more other units, and is able to accept or deliver data in a form (codes or signals) which can be used by the system.

The applicable subheading for the Digital Photo Frame, model number 1103MO, will be 8471.70.6000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Automatic data processing machines and units thereof: Storage units: Other storage units: Not assembled in cabinets for placing on a table, desk, wall, floor, or similar place.” 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 Denise Faingar at 646-733-3010.


Robert B. Swierupski

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