CLA-2-85:OT:RR:NC:N1:109
Mr. Andy Paul D’Amato
Core Brands
1800 S. McDowell Blvd.
Petaluma, CA 94954
RE: The tariff classification of subwoofers from China
Dear Mr. D’Amato: In your letter dated April 8, 2015, you requested a tariff classification ruling. Your request pertains to the classification of three subwoofers identified by brand name “SpeakerCraft Vital.” You reference each subwoofer by SKU and part number and provide a description of same. No samples were submitted with your request. SKU Vital 8, SKU Vital 10, and SKU Vital 12, part numbers ASM99008, ASM99010 and ASM99012, respectively, are single subwoofers used within a home audio system. Each subwoofer contains a built in amplifier (80, 120, and 250 watts) which amplifies the audio signal to play low range frequencies, and a speaker, both of which are mounted within its own cabinet. They are designed to plug directly into an audio receiver or other powered audio source via an RCA cable. Each subwoofer is packaged and sold for retail sale with a power cable and user manual.
You suggest that all three subwoofers be classified under subheading 8519.81.4050, Harmonized Tariff Schedule of the United States (HTSUS), which provides for in pertinent part; “Sound recording or reproducing apparatus…” The items concerned do not actually have a sound reproducing capability, they consist of a speaker and an amplification module, there is no sound reproducing module incorporated within. As such the items concerned are more specifically provided for elsewhere in the tariff. The applicable subheading for all three subwoofers identified as SKU Vital 8, SKU Vital 10, and SKU Vital 12, part numbers ASM99008, ASM99010 and ASM99012, respectively, will be 8518.21.0000, HTSUS, 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. 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 Steven Pollichino at: [email protected]. Sincerely,
Gwenn Klein Kirschner
Director
National Commodity Specialist Division