CLA-2-85:OT:RR:NC:N2 212
Daniel White
Goldensol Music LLC
325 River Road
Modesto, CA 95351
RE: The tariff classification of MIDI Controller from China
Dear Mr. White:
In your letter dated April 23, 2025, you requested a tariff classification ruling.
The merchandise under consideration, identified as the Midi Fighter Twister, is described as a Musical
Instrument Digital Interface (MIDI) controller. The subject device is designed to provide precise, hands-on
control over the digital audio workstations or music producing software. The controller is a compact device
with 16 rotary encoders and each encoder knob is touch-sensitive and can be pressed like a button, allowing
for three distinct functions per knob. Each knob also features RGB LED rings around it to provide visual
feedback, displaying parameter values, levels, or status to enhance the real-time performance and reducing
the need to look at the computer screen.
In use, the device is connected to a computer via USB cable to send MIDI continuous controller messages to
the computer in order to adjust the parameters related to music or sound effects such as volume, filters, EQ,
reverb, and other audio effects in real-time. You state that the device itself is not capable of generating or
mixing sounds and it does not convert analog signals to digital signals. The subject controller acts as a user
interface when connected to a personal computer allowing the user to create, sample, and process music.
In your letter, you suggest that the MIDI Fighter Twister is classified under subheading 8471.60.9050,
Harmonized Tariff Schedule of the United States (HTSUS). We disagree.
As the subject device is performing a sound effects control function and not a data processing function,
classification under subheading 8471.60.9050, HTSUS, is not applicable. Further, in our view the principal
function of the subject device is electronic music control and processing. In Digidesign Inc v. the United
States, Court Number 08-00331, these particular functions were found to be classified under heading 8543,
HTSUS, and not, even if connected to a personal computer, under heading 8471, HTSUS. As such
classification within the suggested heading is not applicable.
The applicable subheading for the MIDI controller, Model name Midi Fighter Twister, will be 8543.70.9860,
HTSUS, which provides for “Electrical machines and apparatus, having individual functions, not specified or
included elsewhere in this chapter; parts thereof: Other machines and apparatus: Other: Other.” The general
rate of duty will be 2.6%.
Effective March 4, 2025, pursuant to U.S. Note 2(u) to Subchapter III, Chapter 99, all products of China and
Hong Kong as provided by heading 9903.01.24, HTSUS, other than products classifiable under headings
9903.01.21, 9903.01.22, and 9903.01.23, HTSUS, will be subject to an additional 20 percent ad valorem rate
of duty. At the time of entry, you must report the applicable Chapter 99 heading, i.e. 9903.01.24, in addition
to subheading 8543.70.9860, HTSUS, listed above.
Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise
must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the
Chapter 99 provisions covering exceptions to the reciprocal tariffs. Products of China, including Hong Kong
and Macau, will be assessed an additional ad valorem rate of duty of 125 percent. Products from all other
countries will be subject to an additional 10 percent ad valorem rate of duty. At the time of entry, you must
report the Chapter 99 heading applicable to your product classification, i.e. 9903.01.63, in addition to
subheading 8543.70.9860, HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 8543.70.9860, 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., 9903.88.02,
in addition to subheading 8543.70.9860, 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 Section 301 trade remedy, 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
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 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 Luke LePage at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division