CLA-2 CO:R:C:M 952271 MBR

Ms. Gail T. Cumins, Esq.
Sharretts, Paley, Carter & Blauvelt
Sixty-Seven Broad Street
New York, NY 10004

RE: Revocation of HQ 087179; Sanyo Audio Systems Models GXT858, ICS620A, and ICS625A; HQ 950882

Dear Ms. Cumins:

On May 31, 1991, we issued HQ 087179, regarding the classification of combination stereos incorporating dual cassette decks. In that ruling we determined that your merchandise (Sanyo Audio Systems Models GXT858, ICS620A, and ICS625A) was classifiable under subheading 8527.31.40, HTSUS, which provides for combination stereos incorporating tape recorders.

On December 10, 1991, and in a subsequent meeting on July 13, 1992, the Electronic Industries Association requested reconsideration of HQ 087179, under the Harmonized Tariff Schedule of the United States (HTSUS).

FACTS:

The combination stereos at issue contain dual cassette tape decks with two tape wells, one of which plays and records, the other of which plays only.

ISSUE:

Are combination stereos incorporating dual cassette decks classifiable under the provision for combination stereos incorporating tape players which are incapable of recording, or are they classifiable under the provision for other combinations incorporating tape recorders?

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LAW & ANALYSIS:

Pursuant to the request submitted by the Electronic Industries Association, we have reconsidered our opinion in HQ 087179, dated May 31, 1991. Based upon our further analysis and research, it is now Customs position that the instant merchandise is classifiable in subheading 8527.31.40, HTSUS, which provides for combinations incorporating tape players which are incapable of recording.

See the attached copy of HQ 950882 for a detailed analysis of our change in classification.

HOLDING:

The Sanyo Audio Systems Models GXT858, ICS620A, and ICS625A, are classifiable in subheading 8527.31.40, HTSUS, which provides for stereo combinations incorporating tape players which are incapable of recording. In accordance with HQ 950882, our prior ruling, HQ 087179 of May 31, 1991, is revoked.

Sincerely,

John Durant, Director
Commercial Rulings Division