Ms. Anna G. Casillas
Sony Electronics Inc.
16530 Via Esprillo
San Diego, CA 92127-1708

RE: The tariff classification of a projector, two speakers, and two storage cabinets from Japan

Dear Ms. Casillas:

In your letter dated April 16, 2014, you requested a tariff classification ruling.

The merchandise under consideration is a projector unit, two speaker units, and two storage cabinets, which together make up the Sony Ultra Short Throw Projector. The projector, speakers, and storage cabinets are all imported in separate packages, in the same shipment, and can be used bedside one another.

This projector can project images between 66 to 147 inches onto a wall by adjusting the built-in 1.6x power zoom lens. This projector contains Sony’s Silicon X-tal Reflective Display (SXRD) chip technology, which is a flat-panel screen device measuring less than 34.29 cm. However, the projector contains neither a television tuner nor any video recording or reproducing apparatus. The speakers, which are mounted in their enclosures, measure about 7.9 inches x 10.4 inches x 21.1 inches.

At the time of importation, the projector is intended to be packaged with a remote control, two AA-size manganese batteries, an AC power cord, two speaker cables, and a user’s manual. When this combination is considered a set for tariff classification purposes, the essential character of the set will be imparted by the projector.

In your request, you suggested classification as a functional unit per Legal Note 4 to section XVI, Harmonized Tariff Schedule of the United States (HTSUS), with the clearly defined function of a projector provided for in subheading 8528.69, HTSUS. However, this merchandise cannot be classified as a functional unit because the subject components are not intended to contribute together to a clearly defined function covered by one of the headings in chapter 84 or chapter 85, i.e., the function of projecting an image onto a wall or a screen. In this case, neither the speakers nor the storage cabinets contribute to this function. This office also considered these components to be a composite good as per General Rule of Interpretation (GRI) 3(b), with the essential character being imparted by the projector of subheading 8528.69, HTSUS. However, since projectors, speakers and storage cabinets are not typically sold together, each component is considered to be of a kind normally offered for sale as a separate part. Furthermore, as a general rule, the components of composite goods are put up in a common packing, which is not the case for the subject merchandise. Therefore, each component should be classified separately.

The applicable subheading for the projector with its accessories, as a set for tariff classification purposes, will be 8528.69.4500, HTSUS, which provides for Monitors and projectors, not incorporating television reception apparatus; … : Projectors: Other: Color: With a flat panel screen: Other: With a video display diagonal not exceeding 34.29 cm. The rate of duty will be Free.

The applicable subheading for the speakers will be 8518.21.0000, HTSUS, which provides for Loudspeakers, whether or not mounted in their enclosures: single loudspeakers, mounted in their enclosures. The rate of duty will be 4.9 percent ad valorem.

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

Your inquiry does not provide enough information for us to give a classification ruling on the storage cabinets. Your request for a classification ruling should include a material breakdown by the composition, e.g., wood, metal, et cetera, the weight of each material, and the cost of each material. When this information is available, you may wish to consider resubmission of your request. We are returning any related samples, exhibits, etc. If you decide to resubmit your request, please include all of the material that we have returned to you.

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


Gwenn Klein Kirschner
Acting Director
National Commodity Specialist Division