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NY N027499

May 13, 2008



TARIFF NO.: 8519.81.4050

Mr. Troy D. Crago
Atico International USA, Inc.
501 South Andrews Avenue
Fort Lauderdale, FL 33301

RE: The tariff classification of an MP3 player with talking pedometer from China.

Dear Mr. Crago:

In your letter dated May 5, 2008, you requested a tariff classification ruling.

The merchandise in question is an MP3 player with talking pedometer, item number A017OA00298. This sound recording and reproducing apparatus measures about 75mm by 63mm by 41.5mm and has 128MB of built-in memory. In addition, this talking MP3 player incorporates a pedometer and an alarm clock. This battery operated apparatus also contains a pleasant voice that announces steps, distance, calories, total exercise time and current time. It can measure up to 99,999 steps, 99,999 calories, 99 hours, 199.99 miles or 199.99 km.

The applicable subheading for the MP3 player with talking pedometer 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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