Tariff classification: e-reader devices treated as finished reading apparatus under Heading 8543, ancillary display functions disregarded.

Classification clarification that the electronic display device (e-reader, Kindle 11th Gen, Model C2V2L3) is classifiable under Sub-heading 8543 70 99: the principal function test and General Rules for Interpretation were applied, with HSN Explanatory Notes and Section Note on multi function machines directing classification by principal function. The device was held to be a finished reading apparatus whose display and communication features are ancillary; accordingly it falls within heading 8543 rather than headings for flat panel display modules, and the applicant's proposed classification is accepted.

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Issues: Whether the Electronic Display Device (E-Reader) (Kindle 11th Gen), Model No. C2V2L3, is classifiable under Sub-heading 8543 70 99 of the First Schedule to the Customs Tariff Act, 1975.

Analysis: The issue concerns classification under the First Schedule to the Customs Tariff Act, 1975 and requires application of the General Rules for Interpretation, Section Notes and HSN Explanatory Notes. The device has been shown to have as its principal function the reading of e-books/newspapers/magazines, with inbuilt ancillary features such as an onboard dictionary and limited Wi Fi connectivity primarily for downloading content. Section Note 3 to Section XVI requires that multi-function machines be classified according to the component or principal function. Chapter and HSN Explanatory Notes indicate heading 8543 covers electrical machines/apparatus having individual functions not specified elsewhere; heading 8524 relates to flat panel display modules designed to be incorporated into other articles and excludes finished products that have assumed the character of other headings. The device is a finished e-reader whose primary purpose is reading, and its communication/display features are ancillary to that principal function. Prior AAR rulings on earlier Kindle models and the applicant's uncontested specifications support that the principal function remains reading despite upgrades.

Conclusion: The Electronic Display Device (E-Reader) (Kindle 11th Gen), Model No. C2V2L3, is classifiable in Sub-heading 8543 70 99 of the First Schedule to the Customs Tariff Act, 1975; the applicant's classification is upheld.

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