H350248

H350248 January 16, 2026 OT:RR:CTF:EMAIN H350248 MNM CATEGORY: Classification TARIFF NO.: 8519.81.41 Center Director Electronics Center of Excellence and Expertise U.S. Customs and Border Protection 1 World Trade Center, Suite 741 Long Beach, CA 90831 Attn: Christopher Roenbeck, Import Specialist Re: Application for Further Review of Protest No. 1401-25-108344; Tariff classification of certain Bluetooth Speakers Dear Center Director: The following is our decision on the Application for Further Review (AFR) of Protest No. 1401-25-108344, which was filed on June 24, 2025, on behalf of Voxx International Corp. (protestant). The Protest and AFR concern the tariff classification of “The One Plus Premium Tabletop Bluetooth Speaker with Broadcast Mode” and “The Three Plus Premium Tabletop Bluetooth Speaker with Broadcast Mode” under the Harmonized Tariff Schedule of the United States (HTSUS). This decision also considers supplemental information received via email from the protestant on November 19, 2025. The subject merchandise was entered on July 15, 2024, and U.S. Customs and Border Protection (CBP) liquidated the entry on June 13, 2025, classifying the merchandise under subheading 8518.22.00, HTSUS, which provides for “Microphones and stands therefor; loudspeakers, whether or not mounted in their enclosures…: Loudspeakers, whether or not mounted in their enclosures…: Multiple loudspeakers, mounted in the same enclosure.” Protestant argues the subject merchandise is properly classified under heading 8519, HTSUS, specifically subheading 8519.81.41, which provides for “Sound recording or reproducing apparatus: Other apparatus: Using magnetic, optical or semiconductor media: Other.” FACTS: “The One Plus Premium Tabletop Bluetooth Speaker with Broadcast Mode,” model number 1071958, and “The Three Plus Premium Tabletop Bluetooth Speaker with Broadcast Mode,” model number 1071961, are Klipsch Heritage wireless speakers that contain a USB-C port that can be used for playback and reverse charging. Both speaker models have a supplementary function of network streaming. In its supplemental submission, the protestant maintains that the merchandise “[a]llows a PC or other host device to connect to the One or Three Plus, which will act as a USB Audio Class Device -or… [t]he USB port can host USB storage class devices for purposes of audio playback. The USB drive audio playback function starts automatically when a USB drive, formatted using the FAT32 file system and containing WAV or MP3 audio files is inserted.” The protestant provided a video that demonstrates inserting a USB thumb drive preloaded with audio files into a Klipsch Heritage Three Plus speaker’s USB input. Immediately, the speaker audibly plays music upon the USB thumb drive’s connection. Additionally, the music audibly stops playing when the USB thumb drive is disconnected from the speaker. The protestant maintains that the subject merchandise incorporates a s semiconductor system-on-chip. In this specific playback mode, the chip acts as the USB mass-storage class host controller, enumerates and mounts the inserted USB thumb drive, reads the file system on the thumb drive and accesses selected audio files, decodes the digital audio data contained in supported file formats (WAV, MP3), and outputs the decoded digital audio stream via I2S format to the internal ACM amplifier ICs. According to the protestant: No external device (phone, computer, etc.) is required for this mode of operation. This implementation effectively gives the devices the capability of a standalone digital audio player when a USB storage device containing audio files is connected, in addition to their primary wireless (Bluetooth) and auxiliary analog input functions. … The product contains no internal user-accessible or user-writable flash memory intended for the storage of music files. All music storage capacity is provided exclusively by the removable USB thumb drive inserted by the user into the rear USB-C host port. ISSUE: Whether the subject One Plus Premium Tabletop Bluetooth Speaker with Broadcast Mode and Three Plus Premium Tabletop Bluetooth Speaker with Broadcast Mode (Klipsch Heritage wireless speakers) are classified under heading 8519, HTSUS, as a sound recording or reproducing apparatus, or under heading 8518, HTSUS, which provides for, in pertinent part, loudspeakers, whether or not mounted in their enclosures. LAW AND ANALYSIS: Initially, we note that the matters protested are protestable under 19 U.S.C. § 1514(a)(2) as decision on classification. The protest was timely filed on June 24, 2025, within 180 days of 2 liquidation of the entries at issue (Miscellaneous Trade and Technical Corrections Act of 2004, Pub.L. 108-429, § 2103(2)(B)(ii), (iii) (codified as amended at 19 U.S.C. § 1514(c)(3) (2006)). Further review of Protest No. 1401-25-108344 is properly accorded to the protestant pursuant to 19 C.F.R. § 174.24(a) because the decision against which the protest was filed is alleged to be inconsistent with a ruling of the Commissioner of CBP or his designee, or with a decision made by CBP with respect to the same or substantially similar merchandise. Classification under the HTSUS is determined in accordance with the General Rules of Interpretation (“GRIs”). GRI 1 provides that the classification of goods shall be determined according to the terms of the headings of the tariff schedule and any relative section or chapter notes. In the event that the goods cannot be classified solely on the basis of GRI 1, and if the headings and legal notes do not otherwise require, the remaining GRIs 2 through 6 will then be applied in order. The 2024 HTSUS provisions under consideration are as follows: 8518 Microphones and stands therefor; loudspeakers, whether or not mounted in their enclosures; headphones and earphones, whether or not combined with a microphone, and sets consisting of a microphone and one or more loudspeakers; audio-frequency electric amplifiers; electric sound amplifier sets; parts thereof: Loudspeakers, whether or not mounted in their enclosures: 8518.22.00 Multiple loudspeakers, mounted in the same enclosure… * * * * * 8519 Sound recording or reproducing apparatus: Other apparatus: 8519.81 Using magnetic, optical or semiconductor media: 8519.81.41 Other… In addition, in interpreting the HTSUS, the Explanatory Notes (ENs) of the Harmonized Commodity Description and Coding System may be utilized. The ENs, although not dispositive or legally binding, provide commentary on the scope of each heading, and are generally indicative of the proper interpretation of the HTSUS. See T.D. 89-80, 54 Fed. Reg. 35127, 35128 (August 23, 1989). The EN to heading 85.18 provides, in pertinent part, the following: This heading covers microphones, loudspeakers, headphones, earphones and audio- frequency electric amplifiers of all kinds presented separately, regardless of the 3 particular purpose for which such apparatus may be designed (e.g., telephone microphones, headphones and earphones, and radio receiver loudspeakers). The heading also covers electric sound amplifier sets. . . . (B) LOUDSPEAKERS, WHETHER OR NOT MOUNTED IN THEIR ENCLOSURES The function of loudspeakers is the converse of that of microphones: they reproduce sound by converting electrical variations or oscillations from an amplifier into mechanical vibrations which are communicated to the air. . . . Matching transformers and amplifiers are sometimes mounted together with loudspeakers. Generally the electrical input signal received by loudspeakers is in analogue form, however in some cases the input signal is in digital format. Such loudspeakers incorporate digital to analogue converters and amplifiers from which the mechanical vibrations are communicated to the air. Loudspeakers may be mounted on frames, chassis or in cabinets of different types (often acoustically designed), or even in articles of furniture. They remain classified in this heading provided the ma

Initially, we note that the matters protested are protestable under 19 U.S.C. § 1514(a)(2) as decision on classification. The protest was timely filed on June 24, 2025, within 180 days of 2 

liquidation of the entries at issue (Miscellaneous Trade and Technical Corrections Act of 2004, Pub.L. 108-429, § 2103(2)(B)(ii), (iii) (codified as amended at 19 U.S.C. § 1514(c)(3) (2006)). Further review of Protest No. 1401-25-108344 is properly accorded to the protestant pursuant to 19 C.F.R. § 174.24(a) because the decision against which the protest was filed is alleged to be inconsistent with a ruling of the Commissioner of CBP or his designee, or with a decision made by CBP with respect to the same or substantially similar merchandise. Classification under the HTSUS is determined in accordance with the General Rules of Interpretation (“GRIs”). GRI 1 provides that the classification of goods shall be determined according to the terms of the headings of the tariff schedule and any relative section or chapter notes. In the event that the goods cannot be classified solely on the basis of GRI 1, and if the headings and legal notes do not otherwise require, the remaining GRIs 2 through 6 will then be applied in order. The 2024 HTSUS provisions under consideration are as follows: 8518 Microphones and stands therefor; loudspeakers, whether or not mounted in their enclosures; headphones and earphones, whether or not combined with a microphone, and sets consisting of a microphone and one or more loudspeakers; audio-frequency electric amplifiers; electric sound amplifier sets; parts thereof: Loudspeakers, whether or not mounted in their enclosures: 8518.22.00 Multiple loudspeakers, mounted in the same enclosure… * * * * * 8519 Sound recording or reproducing apparatus: Other apparatus: 8519.81 Using magnetic, optical or semiconductor media: 8519.81.41 Other… In addition, in interpreting the HTSUS, the Explanatory Notes (ENs) of the Harmonized Commodity Description and Coding System