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NY N013364

July 13, 2007



TARIFF NO.: 8519.81.4050

Mr. Gene Cherniak
Rich Company
4335 Marina City Drive
440 East Tower South
Marina del Rey, CA 90292

RE: The tariff classification of a recorder-player/watch set from China.

Dear Mr. Cherniak:

In your letter dated June 11, 2007, on behalf of Prayer Watch, LLC, you requested a tariff classification ruling.

The subject merchandise, based on the information and sample submitted, consists of a battery-operated recorder-player/watch set that is referred to as the “Message Watch.” This merchandise consists of a digital recorder, which is incorporated in a quartz-analog wrist watch with a base metal case and strap, an extra leather strap, a tool for changing the strap, a charger, and an operation guide, all packed in a cardboard box and imported in a retail-packed condition. The case contains the watch movement, which has no jewels, and the recorder’s IC chip, as well as the speaker and the microphone for the recorder.

It is stated that the sound is stored in the digital recorder-player as a digital signal, which is transferred to voice by a digital/analog (D/A) converter. It has eight alarm settings with 30 seconds of voice-recording time per alarm (as a specific-event alarm or as a regular reminder alarm) and four memory-on-demand memos, e.g., to record ideas or conversations, with 45 seconds of voice time per memo. It is stated that the total time duration of all recordings is approximately 17 minutes and 28 seconds, which includes not only voice alarm and memory memos but also the audio-verbal instructions on setting the recording times.

This merchandise is considered to be a set for tariff classification purposes with the essential character being imparted by the recorder-player/watch. Moreover, it has been determined that the recorder-player/watch is a composite good with the essential character being imparted by the recorder-player based on its value as well as its importance in being advertised as a personal voice-messaging system; furthermore, the bulkiness of the case is also increased by the incorporation of the components comprising the recorder-player.

The applicable subheading for this recorder-player/watch set 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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