CLA-2-84:OT:RR:NC:N1:120

Ms. Marla Lyon
Avid Technology, Inc.
75 Network Drive
Burlington, MA 01830

RE: The tariff classification of HD I/O Audio Interface Devices from China

Dear Ms. Lyon:

In your letter dated August 3, 2010, you requested a tariff classification ruling.

The merchandise under consideration includes three High Definition (HD) Input Output (I/O) Audio Interface Devices, model numbers: 9900-58669-00-HD I/O 8X8X8, 9900-58670-00-HD I/O 16X16 Analog, and 9900-58671-00-HD I/O 16X16 Digital.

Each HD I/O audio interface unit is capable of accepting multi-channel analog audio signals from microphone preamplifiers, electronic musical instruments, analog recording consoles or multi-track audio recorders. The music is input by connecting the actual instruments to the interface unit. The interface unit converts the analog signals (music, voice, sound effects) into data digital signals that are input into an automated data processing machine (ADP) for mixing, editing, real-time processing and storage, etc., and subsequent output to playback or recording units. The interface unit connects to an ADP machine using a proprietary data cable connected to a PCI card installed in the ADP machine. The audio interface devices cannot transmit or receive audio when disconnected from the ADP machine.

Each HD I/O audio interface unit functions with the Pro Tools/HD System software installed on a Windows or Macintosh ADP machine, which allows music to be manipulated through mixing or editing using the ADP system’s keyboard and mouse. The interface unit within itself does not do any mixing, editing or storage. Once the mixing or editing is complete, the finished product can be output back through the interface unit, where it can be converted to analog or digital audio signals and transmitted from the interface unit to amplifiers, amplified monitors, mixers, or other multi channel recording devices, etc.

The HD I/O 8X8X8, 16X16 Analog, and 16X16 Digital audio interface devices are specifically designed for use with a Pro Tools/HD® software running on a personal computer. The Pro Tools® is a Digital Audio Workstation (DAW) platform for Mac operating system (OS) and Microsoft Windows OS. A single HD I/O 8x8x8 provides up to 16 channels of input and output to the computer system

The applicable subheading for the HD I/O Audio Interface Devices will be 8471.80.9000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "Automatic data processing machines and units thereof…Other units of automatic data processing machines: 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 http://www.usitc.gov/tata/hts/.

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 Denise Faingar at (646) 733-3010.

Sincerely,

Robert B. Swierupski
Director
National Commodity Specialist Division