CLA-2-85:RR:NC:MM:109 J84534

Ms. Madeline B. Kuflik
Assistant General Counsel
Panasonic
One Panasonic Way, 3B-6
Secaucus, NJ 07094

RE: The tariff classification of Speakers for Automobiles and/or Boats from Mexico

Dear Ms. Kuflik:

In your letter dated May 9, 2003, you requested a tariff classification ruling on behalf of Matsushita Electronic Components Corporation of America (ACOM).

Your request pertains to the classification of eleven speakers. You make reference to each of the speakers within in your letter as Items A through K. You also associate Items A through K with the Part Numbers listed below. Based on the samples, which were submitted to this office, a description of each speaker is provided next to the corresponding Item and Part Number.

Item Part Number Description A EASA23D19D1A A single loudspeaker (mid-range) not mounted in its enclosure B EABA1405R1 A single loudspeaker (mid-range) not mounted in its enclosure C EASA16PX86A1A Two speakers (mid-range and tweeter) not mounted in its enclosure D EABA1208L1 Two speakers (mid-range and tweeter) mounted in its enclosure E EASA13KH15AL1-B A single tweeter mounted in its enclosure F EASA13KH03AR1 A single tweeter not mounted in its enclosure G EABA708L1 A single loudspeaker (mid-range) mounted in its enclosure H EASA12P09B1 A single loudspeaker (mid-range) not mounted in its enclosure I EABA2010A1 A single subwoofer mounted in its enclosure J EABA1407T1 Kelton box, a single subwoofer mounted in its enclosure K EABA2015T1 A single subwoofer mounted in its enclosure with an amplifier attached on the outside

For Item E (Part Number EASA13KH15AL1-B), you suggested HTS 8518.29.8000, which provides for “Loudspeakers whether or not mounted in their enclosures: Other: Other.” However, Part Number EASA13KH15AL1-B is a single tweeter mounted in its enclosure and is classifiable under Subheading 8518.21, as a single loudspeaker, mounted in its enclosure.

For Item G (Part Number EABA708L1), you suggested HTS 8518.29.8000, which provides for “Loudspeakers whether or not mounted in their enclosures: Other: Other.” Your letter also describes this item as containing 2 speakers (mid-range and tweeter). However, during a telephone conversation I had with you and Mr. Clark Brandon, a representative for ACOM, on June 1, 2003, Mr. Brandon confirmed that there was only one speaker (mid-range) within its enclosure. Therefore, Part Number EABA708L1 is a single loudspeaker mounted in its enclosure and is classifiable under Subheading 8518.21, as a single loudspeaker, mounted in its enclosure.

For Item I (Part Number EABA2010A1), you suggested HTS 8518.29.8000, which provides for “Loudspeakers whether or not mounted in their enclosures: Other: Other.” However, Part Number EABA2010A1 is a single subwoofer mounted in its enclosure and is classifiable under Subheading 8518.21, as a single loudspeaker, mounted in its enclosure.

For Item J (Part Number EABA1407T1), you suggested HTS 8518.29.8000, which provides for “Loudspeakers whether or not mounted in their enclosures: Other: Other.” However, Part Number EABA1407T1, also referenced in your description as a Kelton box, is a single subwoofer mounted in its enclosure and is classifiable under Subheading 8518.21, as a single loudspeaker, mounted in its enclosure.

The applicable subheading for Part Numbers EASA13KH15AL1-B, EABA708L1, EABA2010A1, EABA1407T1, and EABA2015T1 will be 8518.21.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for “Loudspeakers, whether or not mounted in their enclosures: Single loudspeakers, mounted in their enclosures.” The general rate of duty will be 4.9 percent ad valorem.

The applicable subheading for Part Number EABA1208L1 will be 8518.22.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for “Multiple loudspeakers, mounted in the same enclosure.” The general rate of duty will be 4.9 percent ad valorem.

The applicable subheading for Part Numbers EASA23D19D1A, EABA1405R1, EASA16PX86A1A, EASA13KH03AR1, and EASA12P09B1 will be 8518.29.8000, Harmonized Tariff Schedule of the United States (HTS), which provides for “Loudspeakers whether or not mounted in their enclosures: Other: Other.” The general rate of duty will be 4.9 percent ad valorem.

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 n Linda M. Hackett at 646-733-3015.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division