CLA-2-85:OT:RR:NC:N2:209
Andrew Kuhlman
Showcase Holograms LLC
1001 East Villa Street, Unit 4 Pasadena, CA 91106
RE: The tariff classification of a hologram wireless Bluetooth speakers from China
Dear Mr. Kuhlman:
In your letter dated July 15, 2024, you requested a tariff classification ruling.
The item concerned is referred to as a hologram wireless speaker, model number SH11001. This device incorporates two primary components, a Bluetooth speaker to reproduce streamed audio content and a hologram fan which displays holographic content. Both devices are encased within an acrylic see-through housing. The device also has an internal battery to allow several hours of wireless play.
The blades of the fan incorporate light emitting diode (LED) strips. As the fan blade spins, the LED strip produces images that appears to float in midair. In use, the dancing animations will appear to move along with the music being played to enhance the musical experience. The image appears within the see-through acrylic housing, under the Bluetooth speaker.
Audio is streamed from a user’s phone to the speaker. Once the user connects their phone to the speaker via Bluetooth, they can play music on the speaker directly from their phone. The speaker assembly incorporates a single speaker within its housing. There is no music stored on this device. The hologram images are stored on a microSD card within the hologram component.
Based upon the product’s description and use, it is the opinion of this office that the Bluetooth speaker component imparts the principal function to this composite good.
The applicable subheading for the hologram wireless speaker, model number SH11001, will be 8518.21.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Microphones and stands therefor; loudspeakers, whether or not mounted in their enclosures; headphones and earphones, whether or not combined with a microphone, and sets consisting of a microphone and one or more loudspeakers; audio-frequency electric amplifiers; electric sound amplifier sets; parts thereof: Loudspeakers, whether or not mounted in their enclosures: Single loudspeakers, mounted in their enclosures”. 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 8518.21.0000, HTSUS, unless specifically excluded, are subject to an additional 7.5 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.15, in addition to subheading 8518.21.0000, 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, you may refer to the relevant parts of the USTR and CBP websites, which are available at https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and https://www.cbp.gov/trade/remedies/301-certain-products-china, respectively.
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 at https://hts.usitc.gov/.
The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP.
This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection 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, please contact National Import Specialist Steven Pollichino at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division