CLA-2-85:RR:NC:MM:109 J89024

Mr. Brian Walsh
Barnes, Richardson & Colburn
303 East Wacker Drive
Suite 1100
Chicago, IL 60601

RE: The tariff classification of microphone parts from Taiwan and Korea

Dear Mr. Walsh:

In your letter dated October 10, 2003, you requested a tariff classification ruling.

The merchandise is described in your letter as aluminum microphone parts known as “closing rings”. You describe the closing rings within your letter as being circular, approximately one inch in diameter, and between one and two inches in length. The diameter and length vary depending on the microphone in which the rings are used. The rings are threaded on the outside, at each end, with threads of varying widths. The rings are flanged at different places on the inside. The closing rings are incorporated into a microphone sub-assembly called a cartridge. The cartridge includes a sound-driven electrical generator (housed in the closing ring) that is protected by a ball screen. The ball screen screws onto the closing ring, which, in turn, screws into the microphone handle. Two different samples of the closing rings were submitted and have been examined for classification purposes.

You suggest HTS 7616.10.7030, which provides for "Other threaded fasteners, having shanks, threads or holes over 6mm in diameter.” However, these closing rings are not a product of 7616.10.7030 because they are not akin to a screw, bolt, nut, screw hook or similar fastening item. The closing rings are parts of microphones classifiable under Subheading 8518.90, as microphone parts.

The applicable subheading for the closing rings will be 8518.90.8000, Harmonized Tariff Schedule of the United States (HTS), which provides for “Microphones: Parts: Other: Other.” The rate of duty will be 4.9 percent 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 Linda M. Hackett at 646-733-3015.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division