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NY N015365

August 28, 2007



TARIFF NO.: 8519.81.4050

Ms. Francine Ramsey
Hampton Direct Inc.
350 Pioneer Drive
P.O. Box 1199
Williston, VT 05495

RE: The tariff classification of a calculator and voice recorder combination from China.

Dear Ms. Ramsey:

In your letter dated July 27, 2007, you requested a tariff classification ruling.

The subject merchandise is a composite machine that is a calculator and voice recorder combination, SKU number 59770. This battery-powered device, measuring approximately 5 inches by 2 inches by ¾ inch, can perform arithmetic computations and record an eight-second message with a voice playback function.

This merchandise is considered to be a composite machine, which is used both as a recorder and a calculator. Since, a principal function cannot be determined for this composite machine, General Explanatory Note (VI) to Section XVI directs us to apply General Interpretative Rule 3 (c). General Interpretative Rule 3 (c) provides that goods shall be classified under the heading which occurs last in numerical order among those (heading 8470, the calculator, and heading 8519, the voice recorder,) which equally merit consideration. Based on the above, classification of this device will be under heading 8519, HTSUS.

The applicable subheading for the calculator and voice recorder combination 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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