CLA-2-85:OT:RR:NC:N2:212
Amine Sefrioui
Charles Happel, Inc
777 Sunrise Highway, Suite 204
Lynbrook, NY 11563
RE: The tariff classification of music production devices from Malaysia
Dear Mr. Sefrioui:
In your letter dated June 2, 2025, you requested a tariff classification ruling on behalf of your client, Native
Instruments North America, Inc.
There are five items at issue with this request, which are all described as music production devices. The first
is identified as the Kontrol S-Series and further described as a keyboard controller. The subject device
resembles a standard electric keyboard with up to 88 keys, dependent upon the version. The device also
incorporates an LCD display, various rotary encoders, push buttons, touch pad, and wheel selectors. The
keyboard also incorporates various inputs and outputs including USB-C, TRS effect pedal, and MIDI in/out.
In use, the device is programmed to create music through the playing of the keys on the keyboard.
Additionally, the user can add more sounds and music through the loaded software by selecting from
preprogrammed sounds and effects through the various interactive controls. These effects include drum
sounds, orchestral instruments, and synthesizers. Based upon the information provided, no additional input is
needed in order to create music through the keyboard.
In your request, you suggest that the correct classification for the subject keyboard controller is subheading
8543.70, Harmonized Tariff Schedule of the United States (HTSUS). We disagree.
In order for an item to be accurately classified under heading 8543, HTSUS, it must display a function that is
not more appropriately classified elsewhere in the tariff. The subject device closely resembles a traditional
musical keyboard and functions to create music through the interaction with the keys. As such, it is more akin
to a musical instrument than an electrical device under the suggested heading. As such, classification under
subheading 8543.70, HTSUS, is not applicable.
The applicable subheading for the Kontrol S-Series will be 9207.10.0075, HTSUS, which provides for
“Musical instruments, the sound of which is produced, or must be amplified, electrically (for example,
organs, guitars, accordions): Keyboard instruments, other than accordions: Other: With one keyboard: Valued
$100 or over each”. The general rate of duty will be 5.4 percent ad valorem.
The second item at issue with this request is identified as the Maschine MK3 and described as a portable
music production device. The subject device consists of a plastic and metal enclosure upon which is a color
display, eight endless rotary dials, sixteen multicolored touch pads, a multidirectional input encoder, and
sixteen backlit buttons. Additionally, there is an illuminated touch strip and multiple function keys as well as
connectivity for a microphone, headphones, audio MIDI, USB interface, SD memory, and power.
In use, the device is attached to a personal computer and interacts with the Maschine+ software allowing the
user to produce, process, and mix a variety of musical sounds. Music can be created via the preprogrammed
sounds within device or imported through microphone or other attached musical device.
The third item at issue is identified as the Traktor Kontrol S2 and further described as a portable DJ
controller. The device is comprised of two large, rotating jogwheels that resemble the turntables of a
traditional DJ table without the ability to add or play a vinyl record. Additionally, the device incorporates
multiple endless rotary encoders, multicolored touchpads, sliders, and backlit buttons. The device also
incorporates input and outputs for a microphone, speakers, USB devices, and audio MIDI.
In use, the device is used as a DJ board in live music and entertainment venues in order to sample, mix,
synthesize and otherwise blend music and sound. The user can take the sounds and music from the various
inputs and manipulate the speed and pitch, blend tracks together, and further manipulate the music through
the various jogwheels, buttons, and sliders.
The fourth item is identified as the Traktor Kontrol S3 and further described as a DJ controller. We note that
the Kontrol S3 is presented as functioning identically to the S2 stated above. The primary difference between
the two devices is that the S3 is larger and has the ability to connect more input and output devices.
The final item is identified as the Maschine Mikro and further described as a portable music production
device. This device consists of a plastic and metal enclosure and incorporates 16 multicolored lighted
touchpads, a rotary dial, a smart strip, and various other buttons. On the back of the device, there are multiple
input and outputs for connectivity for a microphone, headphones, audio MIDI, USB interface, SD memory,
and power.
The subject device is a smaller version of the MK3 listed above, which displays less features for producing
and altering music through the attached personal computer. The subject device is more compact, thus
allowing it to be a more portable version of the above referenced device. However, we note that the functions
are virtually identical.
In your request, you suggest that the correct classification for the above four devices is also subheading
8543.70, HTSUS. We agree.
The applicable subheading for the Maschine MK3, Traktor Kontrol S2, Traktor Kontrol S3, and Maschine
Mikro 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: Other: Other.” The general rate of duty will be 2.6 percent ad valorem.
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. At this time products from all 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. 9903.01.25, in addition to subheadings
9207.10.0075 and 8543.70.9860, HTSUS, listed above.
The tariffs and additional duties cited above are current as of this ruling’s issuance. 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,
(for)
Steven A. Mack
Director
National Commodity Specialist Division