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

RE: The tariff classification of a media device with keychain from China.

Dear Mr. Crago:

In your letter dated May 14, 2008, you requested a tariff classification ruling.

The subject merchandise, based on the submitted information, is a non-volatile storage media device with a metal keychain, item number A017HA00803, which is referred to as the “USB Digital Bible Keychain.” This device, being a NAND flash drive, is a type of semiconductor media that incorporates 66 chapters of the Bible, which is recorded onto its flash drive prior to shipment to the United States. This media storage device is designed to be inserted into the USB slot of a personal computer for opening the digital version of the Bible’s chapters into the computer’s WordPad. It is stated that this media device is read-only in noting that it cannot accept media from the computer.

This media device, being attached to a metal keychain, is considered to be a composite good for tariff classification purposes with the essential character being imparted by the media device.

The applicable subheading for this media device with keychain will be 8523.51.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Discs, tapes, solid-state non-volatile storage devices, “smart cards” and other media for the recording of sound or of other phenomena, whether or not recorded, including matrices and masters for the production of discs, but excluding products of Chapter 37: Semiconductor media: Solid-state non-volatile storage devices. 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