Ms. Tammie Oliver
Kohl’s Department Stores
N56 W17000 Ridgewood Drive
Menomonee Falls, WI 53051

RE: The tariff classification of a vinyl conversion turntable from China.

Dear Ms. Oliver:

In your letter dated June 24, 2009, you requested a tariff classification ruling.

The subject merchandise, based on the submitted information, is a vinyl conversion USB turntable with dust cover, which is known as the PROFILE LP. This device, which has a plug-and-play USB connection, allows for the recording of vinyl records into the computer’s MP3 files through the use of the EZ vinyl converter software. By transferring records to a digital music library, music can be played on the computer, loaded onto an iPod, or recorded onto a CD. This USB turntable, which does not have any built-speakers nor any automatic record-changing mechanism, can still be connected to a receiver in order to function as a standard turntable.

At the time of importation, this USB turntable will be retail packed with a USB cable and a user’s guide, as well as software, and therefore is considered to be a set for tariff classification purposes, with the essential character being imparted by the turntable.

The applicable subheading for this vinyl conversion turntable will be 8519.30.2000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Sound recording or reproducing apparatus: Turntables (record-decks): 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