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

Mr. Herbert J. Lynch
Sullivan & Lynch, P.C.
Attorneys and Counselors at Law
56 Roland Street, Ste. 303
Boston, MA 02129-1223

RE: The tariff classification of the Bose® Media System from Japan.

Dear Mr. Lynch:

In your letter dated June 19, 2008, on behalf of the Bose® Corporation, you requested a tariff classification ruling.

The subject merchandise, based on the submitted information, is a composite machine that is referred to as the “Bose® Media System,” which is designed for motor vehicle use. It is comprised of an AM/FM tuner, a mutli-format disc player, the uMusic® intelligent playback system and a navigation system, as well as possessing the connectivity capability for a Bluetooth phone, a satellite radio, an iPod and a USB 2.0 device. It is stated that this system is not capable of operating without an external source of power.

In regard to the classification of this composite machine, legal note 3 to section XVI states 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 of performing two or more complementary or alternative functions are to be classified as if consisting only of that component or as being that machine which performs the principal function.

Based on the information and literature submitted, it is the opinion of this office that the principal function of this composite machine is performed by the radio receiver with its high-quality audio functions.

The applicable subheading for the Bose® Media System will be 8527.21.40, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Reception apparatus for radiobroadcasting, whether or not combined, in the same housing, with sound recording or reproducing apparatus or a clock: Radiobroadcast receivers not capable of operating without an external source of power, of a kind used in motor vehicles: Combined with sound recording or 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 Lisa Cariello at 646-733-3014.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division