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Issues: Classification of imported multimedia speakers with additional features such as USB playback and FM radio, and whether the goods were classifiable under heading 8518 as speakers or under headings 8519/8527.
Analysis: The competing tariff entries were examined with reference to the General Rules for the Interpretation of the First Schedule to the Customs Tariff Act, 1975 and Note 3 to Section XVI of the Customs Tariff Act, 1975. The controlling test applied was the principal and main function of the goods. The goods were described and sold as multimedia speakers, and the added USB or FM functions did not change their essential character. The reasoning followed earlier decisions holding that such multifunction speakers remain classifiable as speakers under heading 8518, and Board circulars inconsistent with the statutory classification approach were not treated as overriding the tariff scheme.
Conclusion: The goods were held classifiable under CTH 8518 22 00 as speakers, not under headings 8519 or 8527, and the assessee succeeded.