Application for Further Review of Protest No. 1401-25-108344; Tariff classification of certain Bluetooth Speakers
Active· CBP ruling HQ H350248· Issued 2026-01-16
Ruling text
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 main function of the whole is to act as a loudspeaker. Separately presented frames, chassis, cabinets, etc., also fall in this heading provided they are identifiable as being mainly designed for mounting loudspeakers; articles of furniture of Chapter 94 designed to receive loudspeakers in addition to their normal function remain classified in Chapter 94. The heading includes loudspeakers designed for connection to an automatic data processing machine, when presented separately. . . . The EN to heading 85.19 provides, in pertinent part, the following: This heading covers apparatus for recording sound, apparatus for reproducing sound and apparatus that is capable of both recording and reproducing sound. Generally, sound is recorded onto or reproduced from an internal storage device or media (e.g., magnetic tape, optical media, semiconductor media or other media of heading 85.23). Sound recording apparatus modify a recording medium so that sound reproducing apparatus can subsequently reproduce the original sound-wave (speech, music, etc.). This includes recording based on the receipt of a sound-wave or by other methods, e.g., by recording data sound files, downloaded from an Internet page or a compact disc by an automatic data processing machine, onto the internal memory 4
(e.g., flash memory) of a digital audio device (e.g., MP3 player). Devices which record sound as digital code generally are not capable of reproducing sound unless they incorporate a means for converting the recording from digital code to an analogue signal. *** (IV) OTHER APPARATUS USING MAGNETIC, OPTICAL OR SEMICONDUCTOR MEDIA The apparatus of this group may be portable. They may also be equipped with, or designed to be attached to acoustic devices (loudspeakers, earphones, headphones) and an amplifier. *** (C) Apparatus using semiconductor media This group includes apparatus which use semiconductor (e.g., solid-state non- volatile) media. Sound is recorded as digital code converted from amplified currents of variable intensity (analogue signal) on the recording medium. Sound is reproduced by reading such medium. The semiconductor media may be permanently installed in the apparatus or may be in the form of removable solid- state non-volatile storage media. Examples include flash memory audio players (e.g., certain MP3 players) which are portable battery operated apparatus consisting essentially of a housing incorporating a flash memory (internal or removable), a microprocessor, an electronic system including an audio-frequency amplifier, an LCD screen and control buttons. The microprocessor is programmed to use MP3 or similar file formats. The apparatus can be connected to an automatic data processing machine for downloading MP3 or similar files. Protestant contends that the Klipsch Heritage wireless speakers are classifiable in subheading 8519.81.41, HTSUS, because the speakers are capable of both recording and reproducing sound. According to EN 85.19, the heading covers apparatus for recording sound, apparatus for reproducing sound and apparatus that is capable of both recording and reproducing sound. Generally, sound is recorded onto or reproduced from an internal storage device or media such as magnetic tape, optical media, semiconductor media or other media, which likely would be independently classified under heading 85.23. We note that the tariff does not define “sound reproducing” in the context of heading 8519, HTSUS. In Headquarters Ruling Letter (HQ) H234950, dated December 2, 2014, and HQ H216719, dated July 1, 2013, CBP addressed the definition of “sound reproducing.” In these rulings CBP states that “in order for a device to be a sound-reproducing device, it must be able to read the recorded file, either from an internal memory or from a removable solid state non- volatile media, such as a USB flash memory apparatus.” Consequently, CBP considers a reproducing function the ability to read (play) and decode files from internal media or from media of heading 8523, such as a USB memory device. As per CBP rulings, a USB port with a microprocessor that can read and play back audio files which were stored on semiconductor media, such as a USB memory device, is considered a sound reproducing function. See also HQ 5
H236637, dated June 28, 2013, New York Ruling Letter (NY) N273576, dated March 24, 2016, NY N263612, dated April 21, 2025, and NY N246256, dated September 30, 2013. Based on the information provided by protestant, the merchandise contains a microprocessor that can read and play back audio files stored on semiconductor media, such as a USB memory device, making the Klipsch Heritage speakers capable of performing a sound reproducing function. Specifically, the speakers contain a USB port that “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.” That the protestant’s wireless speakers are capable of reading and playing back audio files stored on a USB memory device demonstrates that the Klipsch Heritage speakers are capable of both recording and reproducing sound. Therefore, the Klipsch Heritage 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 properly classified in subheading 8519.81.41 HTSUS, which provides for “Sound recording or reproducing apparatus: Other apparatus: Other magnetic, optical or semiconductor media: Other.” The classification of the Klipsch Heritage wireless speakers under subheading 8519.81.41 HTSUS, is supported by previous rulings issued by CBP. Specifically, in NY N307209, dated November 15, 2019, CBP classified a similar device in 8519.81.41. Similar to the Klipsch Heritage wireless speakers, the device at issue in NY N307209 was described as Soundbar with Built-in Subwoofers and USB Playback, which “includes a USB port that contains the internal circuitry to read and reproduce audio music files stored on a USB memory device.” HOLDING: By application of GRIs 1 and 6, the subject Klipsch Heritage 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 classified under 8519.81.41, HTSUS , which provides for “Sound recording or reproducing apparatus: Other apparatus: Using magnetic, optical or semiconductor media: Other .” The general, column one rate of duty is Free. This ruling does not address the applicability of any additional duties that may apply to the goods discussed herein. Likewise, duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided at www.usitc.gov. You are instructed to ALLOW the Protest. You are instructed to notify the protestant of this decision no later than 60 days from the date of this decision. Any reliquidation of the entry or entries in accordance with the decision must be accomplished prior to this notification. Sixty days from the date of the decision, the Office of Trade, Regulations and Rulings will make the decision available to CBP personnel, and to the public on the Customs Rulings Online Search System (“CROSS”) at 6
https://rulings.cbp.gov/, which can be found on the CBP website at https://www.cbp.gov and other methods of public distribution.
Sincerely,
for Yuliya A. Gulis, Director Commercial and Trade Facilitation Division 7
Source: rulings.cbp.gov — ruling H350248, retrieved 2026-10-12T05:48:41Z, republished verbatim. This digest is informational; only CBP issues binding rulings.