CLA-2 CO:R:C:G 083065 TLS
Ms. Donna Shira
Sharretts, Paley, Carter & Blauvelt, P.C.
80 Broad Street
New York, New York 10004
RE: Classification of stereo component system
Dear Ms. Shira:
You request a ruling on the proper classification of a
stereo component system under the Harmonized Tariff Schedule of
the United States Annotated (HTSUSA). Your letter dated
September 8, 1988 has been referred to our office for this
purpose.
FACTS:
The inquirer represents a company that wishes to import a
stereo system consisting of different components packaged and
marketed together as one unit. The system includes an
amplifier/tuner with a built-in graphic equalizer, a cassette
recorder/player, a cassette player, a semi-automatic turntable,
two stereo speakers, and a component rack. The cassette player
is incapable of recording sound, as opposed to the
recorder/player, which records as well as plays back sound.
ISSUE:
Is the stereo system properly classifiable under heading
8527, HTSUSA, which covers reception apparatus for
radiotelephony, radiotelegraphy or radiobroadcasting, whether or
not combined, in the same housing, with sound recording or
reproducing apparatus or a clock.
LAW AND ANALYSIS:
The General Rules of Interpretation (GRI) govern the
classification of articles under the HTS. GRI 1 requires that
classification be determined according to the terms of the
-2-
headings and any relative section or chapter notes. The stereo
system is marketed and sold as an item for receiving radio
broadcasts, as well as for reproducing of sound, specifically
music in various forms. The separate components reproduce sound
from different media, including cassette tapes, records, and
AM/FM radio. The common thread between these components is the
fact that the entire system is integrated with the purpose of
reproducing musical sound in stereo. The amplifier/tuner is the
component that is essential to that purpose. Its main function
is to actually receive the radio broadcasts. None of the other
components is functional without the use of the amplifier. This
includes the cassette player, which as noted before, cannot
record sound.
Heading 8527 covers reception apparatus for
radiobroadcasting, whether or not combined with sound recording
or reproducing apparatus. The stereo system receives radio
broadcasts through the tuner and is equipped with a cassette
recorder/player for sound recording. The system is also equipped
with a turntable, a cassette player, and two stereo speakers for
additional sound reproduction. Inasmuch as the amplifier/tuner
is the main component in this system, it constitutes the
principal character of this product. The other components
enhance the versatility and, perhaps, the quality of the system
but can be replaced or done without altogether. The stereo
system would still be capable of performing its radio broadcast
receiving functions. The system is properly classifiable under
heading 8527.
HOLDING:
The stereo system is classified under subheading
8527.31.4000, HTSUSA, as a reception apparatus for
radiobroadcasting or radiotelephony incorporating a tape player
which is incapable of recording.
Sincerely,
John Durant, Director
Commercial Rulings Division