CLA-2:CO:R:C:G 081783 PAM

Ms. Madeline B. Kuflik
Panasonic Company
One Panasonic Way
Secaucus, New Jersey 07094

RE: Tariff classification of a certain Security System

Dear Ms. Kuflik:

Your inquiry of January 6, 1988, concerning the tariff classification of the S-3 Security System under the proposed Har- monized Tariff Schedule of the United States (HTSUS) has been forwarded to Headquarters for disposition. Our ruling on this merchandise follows.


A sample of the S-3 Security System was submitted for analysis. It consist of three components, a closed circuit TV, a voice operated intercom, and a telephone. A unit containing the camera, an audio pickup and a speaker is designed to be attached to the outside of a door. A console containing a telephone and monitor is designed to be used by the occupant of a residence in communicating with people outside the door. The telephone has been adapted to serve as the audio pickup and speaker of the in- tercom. This console and door camera unit are connected by an electric cable. This device functions primarily to facilitate communication between people inside a dwelling and people outside the door of said dwelling. We are guided in determining the classification of this device by Headnote 3 to Section XVI of the HTSUS which indicates that composite machines should be classi- fied as if consisting only of that component which performs the principal function.



Whether this security device should be classified as other telephonic apparatus or as a closed circuit television.


As noted above, composite machines consisting of two or more machines fitted together to form a whole and adapted for the pur- pose of performing two or more complementary or alternative func- tions are to be classified as if consisting only of that compo- nent which performs the principal function. Where such machines are intended to contribute together to a clearly defined function covered by one of the headings in chapter 85, then the whole falls to be classified in the heading appropriate to that func- tion. Headnote 4, Section XVI, HTSUS.

We consider this Security System to be a composite machine in which a camera, intercom, and telephone are fitted together to form a whole and adapted for the purpose of performing two or more complementary or alternative functions. The monitor, tele- phone, and intercom are fitted together in a single unit, and the telephone has actually been adapted to serve as the audio pickup and speaker component of the intercom. The audio and visual com- ponents of this system perform complementary functions by fa- cilitating communication between people inside and people outside a home or residence. Since we consider the functions of these components to be generally complementary in nature, they must be classified according to the principal function of the composite machine.

We also consider the unit designed to be mounted on the out- side of a door to be part of this composite machine by virtue of the fact that it is connected to the console by an electric cable. Headnote 4, Section XVI, HTSUS.

The S-3 Security System functions primarily as an intercom that allows two-way audio and one-way visual communication. The principal function of an intercom is to facilitate communication. Therefore, the S-3 must be classified under the heading appropri- ate to its function as communications equipment.

In choosing between the heading for television cameras and telephone apparatus we consider the latter to encompass the func- tion of this device as communication equipment. The audio por- tion of this apparatus is indispensable to its function as an in- tercom, while the camera and monitor merely enhance that basic function. The S-3 Security System remains an intercom even though a visual component is included in its design.



In view of the foregoing, the applicable HTSUS subheading is 8517.81.00 which provides for other telephonic apparatus, with duty at 8.5 percent ad valorem. Although your letter of January 6, 1988, also requested the classification of this merchandise under the Tariff Schedules of the United States we have not ad- dressed that subject since our New York office provided you with the relevant information in ruling 827541 of February 2, 1988.

As per your request, the sample you submitted is being re- turned under separate cover.


John Durant
Acting Director
Commercial Rulings Division

6cc: Area Director, New York Seaport
2cc: Chief, CIE
1cc: John Durant