Mr. Troy D. Crago
Atico International USA, Inc.
501 South Andrews Avenue
Fort Lauderdale, FL 33301

RE: The tariff classification of a radio receiver with various functions from China.

Dear Mr. Crago:

In your letter dated May 8, 2008, you requested a tariff classification ruling.

The subject merchandise, based on the submitted information, is a small, portable, battery-operated FM radio receiver, item number A017OA00297, with a built-in voice recorder (operating through semiconductor media), as well as a built-in MP3 Player and pedometer. This device, which has a built-in LCD screen, also incorporates a stopwatch function and a real-time clock display, as well as an earphone jack and a USB port. It is stated that this device is being imported in a retail-packed condition with detachable clip, stereo earphone, USB cable and user’s guide.

The subject merchandise is considered to be a set for tariff classification purposes with the essential character being imparted by the radio receiver having the above-stated functions. It should be noted that this radio receiver (capable of recording and reproducing) which is combined with a pedometer as well as clock and watch functions, is a composite good; furthermore, the essential character of this composite good is imparted by the radio receiver with recording and reproducing apparatus.

The applicable subheading for this radio receiver with various functions will be 8527.13.6080, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Reception apparatus for radiobroadcasting, whether or not combined, in the same housing, with sound recording or reproducing apparatus or a clock: Radiobroadcast receivers capable of operating without an external source of power: Other apparatus combined with sound recording or reproducing apparatus: Other: Other: 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 Lisa Cariello at 646-733-3014.


Robert B. Swierupski
National Commodity
Specialist Division