CLA-2-84:RR:NC:1:110 D82729
Mr. Jeff M. Flood
AEI Brokers
2325 South 200th Street
SeaTac, WA 98198
RE: The tariff classification of a GVOX guitar interface device
from Taiwan
Dear Mr. Flood:
In your letter dated September 16, 1998, on behalf of Lyrrus
Inc., you requested a tariff classification ruling.
The merchandise under consideration involves a GVOX guitar
system interface device that connects the guitar to a computer to
interactively learn and practice guitar. The unit is used as a
MIDI interface between a guitar and a computer, allowing the
guitar player to record, write and play along with guitar
tutorials.
The components of this system includes the following: a G-VOX processor; G-VOX pickup device; G-VOX dock; G-VOX
screwdriver; AC adapter; adapter plug, and two CD-ROM software
disks. The G-VOX pickup is designed to fit under the strings of
any guitar, while the G-VOX processor receives signals from the
pickup, translates them into computer language, and sends the
information to the computer's serial port. To run the software,
the computer must have at least a 486-33 MHZ or faster processor,
Windows 95, 8 MB of RAM, Windows compatible sound card, 256
colors, and 640 x 480 resolution.
The components of this G-VOX interactive system are packaged
and sold as a retail set for retail sale. Noting GRI-3 (b), this
retail set would thus be classifiable as if it consisted of the
material or components which gives them their essential
character. The G-VOX processor, by function, use, and value,
would exemplify the essential character of this retail set. The
G-VOX processor device is basically a signal converting device
and also meets the definition of a "unit" of an ADP system, as
per Legal note 5 (B) to Chapter 84 of the HTS. Please note also
HQ ruling 956208 and NY ruling 814235 for similar merchandise.
Although classifiable as a retail set, the CD-ROM software would
be separately classifiable, noting Legal Note 6 to Chapter 85 of
the HTS.
The applicable subheading for the G-VOX guitar interface
system will be 8471.80.9000, Harmonized Tariff Schedule of the
United States (HTS), which provides for other units of automatic
data processing machines. The rate of duty will be free.
The applicable subheading for the CD-ROM software will be
8524.39.4000, HTS, which provides for other discs for laser
reading systems, for reproducing representations of instructions,
data, sound, and image, recorded in a machine readable form, and
capable of being manipulated or providing interactivity to a
user, by means of an ADP machine. The rate of duty will be 1.9
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 Art
Brodbeck at 212-466-5490.
Sincerely,
Robert B. Swierupski
Director,
National Commodity
Specialist Division