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NY M83260




June 1, 2006

CLA-2-85: RR: NC: 1:108 M83260

CATEGORY: CLASSIFICATION

TARIFF NO.: 8519.99.00

Mr. Joseph Hoffacker
Barthco Trade Consultants
5101 S. Broad Street
Philadelphia, PA 19112-1404

RE: The tariff classification of a karaoke machine from China.

Dear Mr. Hoffacker:

In your letter dated May 19, 2006, on behalf of The Singing Machine Co., Inc., you requested a tariff classification ruling.

The item in question is a karaoke machine denoted as model number STVD-1001. The karaoke machine incorporates a DVD/CDG karaoke system, a video camera, a 7” black and white monitor and tower speakers. It enables the user to sing along to musical melodies while the lyrics appear on the monitor. It does not contain a sound recording device.

Legal Note 3 to section XVI states and requires “That unless the context otherwise requires, composite machines consisting of two or more machines fitted together to form a whole and other machines designed for the purpose or performing two or more complementary functions or alternative functions are to be classified as if consisting only of that component or as being that machine that performs the principal function”. This office considers the karaoke machine; model STVD-1001 to be a composite machine in accordance with Legal Note 3 to Section XVI.

It is the opinion of this office that the principal function of this karaoke machine is as a sound-reproducing device (note HQ Ruling 966608). Classification will be accordingly.

The applicable subheading for the karaoke machine, model STVD-1001 will be 8519.99.00, Harmonized Tariff Schedule of the United States (HTSUS), which provides for turntables, record players, cassette players and other sound reproducing apparatus, not incorporating a sound recording device: Other sound reproducing apparatus: Other. The rate of duty will be free.

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 World Wide Web at http://www.usitc.gov/tata/hts/.

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 Michael Contino at 646-733-3014.

Sincerely,

Robert B. Swierupski
Director,

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