CLA-2-94:OT:RR:NC:N4:433

James M. Dean
Member
Denver Music Group
7717 S. Cove Circle
Centennial, CO 80122-3375

RE: The tariff classification of amplifiers, drum seats, a tactile transducer, cases and tripods; country of origin for each item is unspecified.

Dear Mr. Dean:

In your letter dated November 28, 2014, you requested a tariff classification ruling. Descriptive and illustrative literature were provided.

You state that it is your intention to import Porter & Davies LTD musical amplification products to be distributed to music retailers by Denver Music Group. The amplifiers will produce the signal and the drum seats with transducer style speakers will produce the sound. The amplifiers will come in as finished product and the drum seats will come in as partially finished products.

For purposes of this ruling, there are three separate amplifiers that have the same essential function but have 3 different designs. As identified below, they are the BC2, the BC2rm, and the BC Gigster:

BC2 by Porter and Davies “Engine” Flightcase Amp (with all leads and accessories):

Dimensions: 30cm x 30cm x 30cm inc ball corners

Weight: 9.5Kg

Cables supplied as standard: 2M UK, Euro and US power cables plus 2M Speakon NL4 throne link cable

230/115vAC switchable

Mic in: 600 ohm electronically balanced P2 hot XLRF +48v Phantom power switch with indicator Mic out: Hardwired parallel to mic in. XLRM Line in: 10K ohm electronically balanced P2 hot XLRF Low Contour: +/- 12dB @ 45Hz shelving

Signal present indicator led, green: -30dB Signal Peak indicator led, red: +4dB

Max output: 150W RMS / 4ohm 0.05%THD 20hz-18khz +/- 2dB. Anti-thump and 2 stage

BC2rm by Porter and Davies “Engine Amp”:

The BC2rm is the latest addition to the Porter & Davies family. It has the same features, power and performance as the regular BC2 engine, but is in a 2U 19” rack-mount layout. Like the flight-cased BC2 and lightweight, streamlined Gigster, the BC2rm system delivers Stealth Monitoring technology that enables users to hear and feel their drums internally via the company’s innovative Bone Conduction techniques (thus the BC name).

BC Gigster by Porter and Davies “Engine”:

Dimensions: 34cm x 16cm x 10cm inc rubber bumpers

Weight: 3.4Kg Cables supplied as standard: 2M UK power cable - fixed (Euro and US coming soon) 2M Speakon NL4 throne link cable. Twin Axial, 140 x 0.15mm, OFC

Amp Specs --

230vAC (115vAC [USA etc] coming soon) 200W peak

Self-selecting combination XLR/JACK input

Plug in an XLR for: Mic in: 600 ohm electronically balanced P2 hot XLRF Plug in a JACK for: Line in: 10K ohm unbalanced tip: hot Mic out: Hardwired parallel to mic in. XLRM balanced P2 hot Line out: Hardwired parallel to line in. XLRM unbalanced P2 hot

Input gain: Mic: 0dB to +60dB Line: -20dB to +40dB

Low Contour: +/- 12dB @ 55Hz shelving

Signal Present indicator led, green: -30dB Signal Peak indicator led, yellow: 0dB Signal Limit indicator led, red: +12dB

Max output: 150W RMS / 4ohm 0.05%THD 20hz-18khz +/- 2dB. Anti-thump and noiseless dynamic load protection circuitry built-in The applicable subheading for the BC2, the BC2rm and the BC Gigster amplifiers will be 8518.40.2000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Microphones and stands therefor; loudspeakers, whether or not mounted in their enclosures; headphones and earphones, whether or not combined with a microphone, and sets consisting of a microphone and one or more loudspeakers; audio-frequency electric amplifiers; electric sound amplifier sets; parts thereof: Audio-frequency electric amplifiers: Other.” The rate of duty will be 4.9% ad valorem, if manufactured in a country falling within column 1 duty rates.

For purposes of this ruling, there are two models of drum seats. The BC2 and the BC Gigster. Each one comes in three different shapes. These are: Round, Saddle and Bench. They will come in {without} the transducer speaker mounted in the seat. The seats will consist of foam and wood covered by vinyl and crushed velvet. Each will have a bolt mounted inside to hold the transducer.

Round Throne Top: 40 x 40 x 24cms deep Weight: 5.7Kg with transducer installed

Saddle Throne Top 40 x 40 x 24cms deep Weight: 5.7Kg with transducer installed

Extra-wide Throne Top 50 x 40 x 24cms deep Weight: 5.9Kg with transducer installed

The applicable subheading for the BC2 and the BC Gigster seats, whether or not incorporating a sound system, will be 9401.61.6031, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Seats (other than those of heading 9402), whether or not convertible into beds, and parts thereof: Other seats, with wooden frames: Upholstered: Other: Other.” The rate of duty will be free, if manufactured in a country falling within column 1 duty rates.

For purposes of this ruling, model number PDN.PDTT2.4 is described as a tactile transducer. Porter & Davies, has partnered with a British company, Precision Devices, to produce their own bespoke dedicated tactile transducers, developed from the ground up. A tactile transducer or "bass shaker" is a device which is made on the principle that low bass frequencies can be felt as well as heard. A shaker transmits low-frequency vibrations into various surfaces so that they can be felt by people. This is called tactile sound. Tactile transducers may augment or in some cases substitute for a subwoofer.

A bass-shaker is meant to be firmly attached to some surface such as a seat, couch or floor. The shaker houses a small weight which is driven by a voice coil similar to those found in dynamic loudspeakers. The voice-coil is driven by a low-frequency audio signal from an amplifier; common shakers typically handle 25 to 150 watts of amplifier power. The voice coil exerts force on both the weight and the body of the shaker, with the latter forces being transmitted into the mounting surface.

The applicable subheading for the PDN.PDTT2.4, tactile transducer, will be 8543.70.4000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electrical machines and apparatus, having individual functions, not specified or included elsewhere in this chapter; parts thereof: Other machines and apparatus: Electric synchros and transducers; flight data recorders; defrosters and demisters with electric resistors for aircraft.” The rate of duty will be 2.6% ad valorem, if manufactured in a country falling within column 1 duty rates.

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/.

At this time, we do not have enough information to rule upon the cases or the tripods. Upon submission of additional information and samples, this office will issue a binding ruling. The following additional information is needed:

Representative samples of the cases and tripods as imported, preferably in their packaging boxes or containers. If available, provide the model number, product number or SKU assigned to those goods.

Color photos of the cases and tripods, associated with their model number, product number or SKU.

Descriptive or technical literature for the cases and tripods. Any marketing or advertising literature for the cases and tripods.

Explain the function and use for the cases and tripods. Are the cases or tripods specifically designed to either house their seats or hold their machines or apparatus?

Breakdown of materials by composition (i.e., metal, plastic textile, etc.), weight of each material and cost of each material.

For each case or tripod identify the country of origin.

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 Neil H. Levy at E-mail address: [email protected].

Sincerely,

Gwenn Klein Kirschner
Director
National Commodity Specialist Division