CLA-2-84:OT:RR:NC:N2:220

Karen Hilliker
Avid Technology, Inc.
75 Network Drive
Burlington, MA 01803

RE: The tariff classification of the MBOX Studio from China

Dear Ms. Hilliker:

In your letter dated September 30, 2022, you requested a tariff classification ruling.

The merchandise under consideration is identified as the MBOX Studio USB Audio Interface (MBOX), which is described as an enclosure having multiple audio control and/or user interface features on the top, and on the rear are numerous input and output sockets and connections. The function of the MBOX is to connect directly to an automatic data processing (ADP) machine for the purpose of editing audio files, where users have the ability to attach various electronic devices, such as musical instruments, microphones, pedals, keyboards, etc. to the MBOX and through the software residing on the ADP machine, edit the files. The MBOX is imported in a retail package containing the MBOX Studio, USB cables, a power adapter, and documentation.

In your request, you suggest the MBOX is classifiable under heading 8471, Harmonized Tariff Schedule of the United States (HTSUS), and cite HQ W968368, which classified previous versions of the MBOX, as supporting documentation. We agree.

The applicable subheading for the MBOX Studio USB Audio Interface will be 8471.80.9000, which provides for “Automatic data processing machines and units thereof…: Other units of automatic data processing machines: Other: Other.” The general rate of duty will be Free.

Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 8471.80.9000, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.03, in addition to subheading 8471.80.9000, HTSUS, listed above.

The HTSUS is subject to periodic amendment, so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, including information on exclusions and their effective dates, you may refer to the relevant parts of the USTR and CBP websites, which are available at the following addresses:

https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions https://www.cbp.gov/trade/remedies/301-certain-products-china

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 the World Wide Web at https://hts.usitc.gov/current.

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 Karl Moosbrugger at [email protected].

Sincerely,

Steven A. Mack
Director
National Commodity Specialist Division