Ms. Tamra S. Nelson
Import/Export Compliance Supervisor
Belkin International, Inc.
501 W. Walnut Street
Compton, CA 90220

RE: The tariff classification of a TuneFM™ for iPod® nano, a TuneBase™ FM for iPod® nano, and a TuneCast™ Mobile FM Transmitter from China

Dear Ms. Nelson:

In your letter dated March 12, 2007 you requested a tariff classification ruling.

The merchandise subject to this ruling is a TuneFM™ for iPod® nano, a TuneBase™ FM for iPod® nano, and a TuneCast™ Mobile FM Transmitter. Each of these three devices is a radiotelephony point-to-point wireless transmitter for an iPod nano, an iPod, other music players, and personal or laptop computers. Once either of the transmitters is connected to one of these devices, they enable the user to hear pre-recorded music files through the speakers within a car or a home or portable stereo. The TuneFM™ for iPod® nano, a TuneBase™ FM for iPod® nano, and a TuneCast™ Mobile FM Transmitter are one-to-one closed communication devices for radiotelephony (wireless) communications and not transmitters used for radiobroadcasting over a broad geographic area, with the intention of reaching a broad audience, such as in a one-to-many system, which is open to all.

The TuneFM™ for iPod® nano is identified in your letter as Part # F8Z061-BLK. It wirelessly connects your iPod® to your car, home or portable stereo enabling the pre-recorded music to be heard through the car, home or portable stereo’s speakers. The TuneFM™ plugs into the dock connector of an iPod® nano. The user then tunes the stereo to a clear FM frequency and the pre-recorded music on the iPod is heard through the speakers.

The TuneBase™ FM for iPod® nano is identified in your letter as Part # F8Z063-BLK. It contains a built-in FM wireless transmitter that connects to your car stereo on multiple FM channels, from 88-1MHz to 107.9 MHz. The pre-recorded contents (music files) of a iPod® nano is transmitted through an FM channel and the TuneBase™ FM allows the user to chose the best available frequency for listening to the music files through a car’s stereo speakers. This wireless device features four single-touch programmable preset memory buttons, which enable the user to find the clearest frequencies and toggle among them for best performance/reception. This item sits in a swivel holder cradle with a flexible steel neck that is connected to a car power adapter. The flexibility of the steel neck enables the user to vary the positioning of the iPod® nano.

The TuneCast™ Mobile FM Transmitter is identified in your letter as Part # F8V367-APL. It enables the user to listen to the pre-recorded tunes (music files) from an iPod® mobile digital device through an FM stereo receiver. The TuneCast™ Mobile FM Transmitter wirelessly connects portable music players to a car or home stereo. It plugs into the headphone jack of an iPod® or any audio source, such as a PDA, MP3, CD or cassette player, or a personal or laptop computer. Once a clear FM frequency is tuned-in, the music coming from each of these devices can be heard through the car or home stereo’s speakers.

The applicable subheading for the TuneFM™ for iPod® nano (Part # F8Z061-BLK), a TuneBase™ FM for iPod® nano (Part # F8Z063-BLK), and a TuneCast™ Mobile FM Transmitter (Part # F8V367-APL) will be 8517.69.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Other apparatus for transmission or reception of voice, images or other data, including apparatus for communication in a wired or wireless network (such as a local or wide are network): 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

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 Linda M. Hackett at 646-733-3015.


Robert B. Swierupski
National Commodity
Specialist Division