CLA-2-85:RR:NC:H89506

Mr. Stephen W. Marlow
Tower Group International , Inc.
205 West Service Road
Champlain, New York 12919

RE: The tariff classification of digital video recorders.

Dear Mr. Marlow:

In your letter dated March 19, 2002 you requested, on behalf of your client BreconRidge Manufacturing Solutions, a tariff classification ruling.

The literature, which you have submitted, states that the (March Networks DVR 4250 and DVR 4120) products are digital video recorders. The products are described as networked digital video recording devices with imputs for cameras, alarms, audio channels, and expanded storage capacity. The devices function by recording the real time video activity of LAN or WAN networks. The captured video is stored on the device hard drive using a compression protocol.

The applicable subheading for the March Networks DVR 4250 and DVR 4120 will be 8521.90.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for Video recording or reproducing apparatus, whether or not incorporating a video tuner: Other. The rate of duty will be free.

This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177).

A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist Michael Contino at 646-733-3014.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division