CLA-2-85:OT:RR:NC:N2:209

Anna G. Casillas
Sony Electronics Inc.
16535 Via Esprillo
San Diego, California 92127

RE: The tariff classification of a Soundbar Speaker System from either China or Vietnam

Dear Ms. Casillas:

In your letter dated April 22, 2022, you requested a tariff classification ruling.

The item concerned is referred to as the Sony Soundbar Speaker System HT-G700. In its imported condition, it consists of a Soundbar (Model SA-G700), a Subwoofer (Model SA-WG700), a remote control, 2 power cords, an HDMI cable, and printed instruction materials.

The soundbar incorporates an advanced surround technology to reproduce the latest theater audio formats like Dolby Atmos®/DTS:X™. Its three front speakers combine with Sony’s unique signal processing, reproduce "vertical" audio, and create virtual surround sound.

The subwoofer, which receives a wireless audio signal from the soundbar delivers a deep, rich bass sound. The soundbar can wirelessly connect to ten compatible devices at one time.

The Soundbar Main Unit Model SA-G700 is comprised of the following elements:

Three 100W power output, 45mm x 100mm cone type, loudspeakers mounted in the same enclosure. (front left, front right, and center speaker) Three digital amplifiers. (Sony S-master technology) Digital sound processor. (Vertical Surround Engine) Bluetooth receiver/transmitter. Power button, Input select button, Bluetooth button and – / + volume buttons. Bluetooth indicator light, Front indicator panel display and remote-control sensor. One “HDMI IN” and One “OPTICAL TV IN” Input Connectors. One HDMI OUT – Output Connector. One USB connector used ONLY for software update. One AC inlet. Dimensions W/H/D. 980 x 64 x 96 The Subwoofer Model SA-WG700 is comprised of the following elements:

One 100W power output, 160mm cone type, loudspeaker mounted in one enclosure. One digital amplifier. Wireless Bluetooth receiver. Power button and LINK button. Power indicator light. One AC inlet. Dimensions W/H/D. 192 x 387 x 406

Neither the soundbar nor the subwoofer can read audio files from or record to a semiconductor medium (e.g., USB Drive). Further, neither can receive FM/AM radio signals.

This system would be considered a functional unit used to reproduce sound. As such the applicable subheading for the Sony Soundbar Speaker System HT-G700 will be 8518.22.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Microphones and stands therefor; loudspeakers, whether or not mounted in their enclosures…: Loudspeakers, whether or not mounted in their enclosures: Multiple loudspeakers, mounted in the same enclosure.” The general rate of duty will be Free.

Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 8518.22.0000, HTSUS, unless specifically excluded, are subject to an additional 7.5 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.15, in addition to subheading 8518.22.0000, HTSUS, listed above. The HTSUS is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, you may refer to the relevant parts of the USTR and CBP websites, which are available at https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and https://www.cbp.gov/trade/remedies/301-certain-products-china, respectively.

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 the World Wide Web at https://hts.usitc.gov/current.

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,

Steven A. Mack
Director
National Commodity Specialist Division