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.