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NY E88224





October 28, 1999

CLA-2-85:RR:NC:MM:109 E88224

CATEGORY: CLASSIFICATION

TARIFF NO.: 8517.80.1020; 8518.30.2000

Mr. Thomas W. Phalen
Vice President, Tax and Customs
Plantronics, Inc.
345 Encinal Street
Santa Cruz, CA 95060

RE: The tariff classification of CA 10 Adapter and the CS 10 telephone headset system from South Korea

Dear Mr. Phalen:

In your letter dated September 14, 1999, you requested a tariff classification ruling.

The merchandise is described in your letter and submitted descriptive literature as the CA 10 Adapter and the CS 10 telephone headset system. This merchandise will be imported as sets for retail sale. They are accessory type sets that expand the functionality of a standard line telephone. They are designed as Small/Home Office (SOHO) solutions. The CA 10 Adapter set contains a 900 MHz base unit that connects by line to the telephone, a remote unit, and an AC Adapter. The remote unit is designed to connect to a headset (not supplied with this set). It can be clipped onto a belt. The base unit interfaces with the line telephone. Both the base and the remote contain radio frequency receivers and transmitters, and amplifiers. The remote has a volume control, talk button, channel button, and mute button. The remote is designed to recharge while sitting in a slot on the base. The AC adapter provides power for the adapter. The CA 10 Adapter is designed to connect by line through a standard telephone to the Public Switched Telephone Network (PSTN). In accordance with GRI 3 (b) it would be classified in heading 8517.

The CS 10 telephone headset system contains the CA 10 Adapter as previously described and a Plantronics headset. Headsets are goods of heading 8518. The CS 10, which includes a headset, is designed to provide for hands free operation and to connect by line through a standard telephone to the Public Switched Telephone Network (PSTN). Since no component provides the essential character of this set, GRI 3 (c) would apply. It would be classified under the heading that occurs last in numerical order of those which merit equal consideration. Headings 8517 and 8518 are the headings that merit equal consideration.

The applicable subheading for the CA 10 Adapter will be 8517.80.1020, Harmonized Tariff Schedule of the United States (HTS), which provides for “[e]lectrical apparatus for line telephony or line telegraphy[o]ther apparatus: [t]elephonic: [o]ther.” The rate of duty will be 2.1% ad valorem.

The applicable subheading for the CS 10 telephone headset system will be 8518.30.2000, Harmonized Tariff Schedule of the United States (HTS), which provides for “[h]eadphones, earphones and combined microphone/speaker sets: [o]ther.” The rate of duty will be 4.9% ad valorem.

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 Eileen S. Kaplan at 212-637-7048.

Sincerely,

Robert B. Swierupski
Director,

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