In ruling NY N312344 (July 7, 2020), Customs and Border Protection (CBP) discussed the classification of a vinyl record recorder, the “PHONOCUT.” It records audio onto vinyl records from any analog audio source, such as the output of a smartphone.  Once an audio source is plugged into the “PHONOCUT,” the user pushes a button and sound is recorded onto a vinyl record.  This device has a cutting head that contains transducers that vibrate the diamond stylus, which cuts the appropriate grooves into the disc.  The finished vinyl records are playable on any standard phonograph record player; however, the “PHONOCUT” itself cannot reproduce sound .

CBP determined the applicable subheading for the “PHONOCUT” will be 8519.89.3000, HTSUS, which provides for Sound recording or reproducing apparatus: Other apparatus: Other: Other.  The rate of duty will be Free.

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Photo of Frances P. Hadfield Frances P. Hadfield

Frances P. Hadfield is a counsel in Crowell & Moring’s International Trade Group in the firm’s New York office. Her practice focuses on forced labor and withhold release orders (WRO), import regulatory compliance, and customs litigation. She regularly advises corporations on matters involving…

Frances P. Hadfield is a counsel in Crowell & Moring’s International Trade Group in the firm’s New York office. Her practice focuses on forced labor and withhold release orders (WRO), import regulatory compliance, and customs litigation. She regularly advises corporations on matters involving customs compliance, audits, customs enforcement, as well as import penalties.

Frances represents clients before the U.S. Court of International Trade and the U.S. Court of Appeals for the Federal Circuit, as well as in proceedings at the administrative level. She advises corporations on both substantive federal and state regulatory issues that involve U.S. Customs and Border Protection, the Federal Trade Commission, Food and Drug Administration, and U.S. Fish & Wildlife in matters pertaining to product admissibility, audits, classification, import restrictions, investigations, marking, licenses, origin, penalties, and tariff preference programs.

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