OT:RR:CTF:CPMMA H335012 LLO
TARIFF No.: 9620.00.70
Ms. Ewa Szczepanski
Casio America, Inc.
570 Mt. Pleasant Avenue
Dover, NJ 07801
Re: Request for Binding Ruling; Classification of Casio Colpocamera Stand model
number CST-100M
Dear Ms. Szczepanski:
This is in response to your request, on behalf of Casio America, Inc., for a binding
ruling regarding the classification of the Casio Colpocamera folding camera stand, model
number CST-100M, under the Harmonized Tariff Schedule of the United States
(HTSUS). The original ruling request was made on June 22, 2023, to the National
Commodity Specialist Division (NCSD), New York, and was assigned New York Ruling
case number (NY) N333652, which requested additional information from you and was
closed by the NCSD. On or about September 21, 2023, you resubmitted the ruling
request to the NCSD which in turn forwarded the request to this office for decision. Our
ruling is set forth below.
FACTS:
The Casio Colpocamera camera stand, model number CST-100M, is a folding,
five-legged stand on casters that has a counterweighted, moveable arm to which Casio’s
Colpocamera 1 can be mounted. Hand grips, the adjustable arm and casters enable
medical professionals to situate the camera in optimal position to observe and capture
images of colposcopies. You indicate that the country of origin is Japan. The
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The Colpocamera consists of a complementary metal oxide semiconductor (CMOS) image sensor, lens, flash
memory, a microphone, a speaker, an liquid crystal display (LED) light source fitted with green and polarizing filters,
and a Wi-Fi (wireless LAN) component in one housing with a 3” touch-sensitive LCD display/monitor, a power button,
an EV button (brightness adjustment), a shutter, a zoom button, a mode button, a play button, a battery compartment,
a memory card slot, a USB port, an HDMI port, a DC jack, and a tripod mount (camera stand mounting hole). The
camera can shoot still images and videos and record them onto both internal memory and an SD card.
dimensions of the folded stand are 513 millimeters (mm) in diameter and 924 mm in
height. The stand’s arm extends to approximately 300 mm in diameter. The stand is
made primarily of aluminum and weighs 13.3 kilograms (29.3 pounds).
You indicate that the main function of the stand is to provide stability for the
camera during its use by a medical professional. This specially designed stand also
allows for smooth and precise camera movement and easy positioning during
observation and use. The stand is used to stabilize the camera, allowing the user to
capture images without having to handle the Colpocamera and to avoid unintended
movements and resultant unclear images. This stand is similar in design and use to a
tripod, but with five legs, which stabilize the Colpocamera and eliminate movement to
enhance image quality. Once the stand is in position, it remains in place until
repositioned by the user.
ISSUE:
Whether the instant camera stand is classified in heading 9006, HTSUS as
photographic (other than cinematographic) cameras; photographic flashlight apparatus
and flashbulbs other than discharge lamps of heading 8539; parts and accessories
thereof; or in heading 9620, HTSUS, as monopods, bipods, tripods and similar articles:
of aluminum.
LAW AND ANALYSIS:
Merchandise is classifiable under the HTSUS in accordance with the General
Rules of Interpretation (GRIs). GRI 1 provides that classification shall be determined
according to the terms of the headings and any relative Section or Chapter Notes. In the
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event that the goods cannot be classified solely on the basis of GRI 1, and if the
headings or notes do not require otherwise, the remaining GRIs 2 through 6 may then be
applied in order.
The HTSUS provisions under consideration are as follows:
9006 Photographic (other than cinematographic) cameras; photographic
flashlight apparatus and flashbulbs other than discharge lamps of heading
8539; parts and accessories thereof:
Parts and accessories:
9006.91.00 For cameras.
****
9620.00 Monopods, bipods, tripods and similar articles:
9620.00.70 Of aluminum
The Harmonized Commodity Description and Coding System Explanatory Notes
(ENs) constitute the official interpretation of the Harmonized System at the international
level. While neither legally binding nor dispositive, the ENs provide a commentary on the
scope of each heading of the HTSUS and are generally indicative of the proper
interpretation of these headings at the international level. See T.D. 89-80, 54 Fed. Reg.
35127, 35128 (August 23, 1989).
The Explanatory Note to Chapter 90 provides in pertinent part that:
1. – This Chapter does not cover:
(l) Monopods, bipods, tripods and similar articles, of heading 96.20[.]
The Explanatory Note to Heading 90.06 provides in pertinent part as follows:
Parts and Accessories
…
[M]onopods, bipods, tripods and similar articles are, however, excluded (heading 96.20).
(Emphasis in the original.)
Legal Notes 1(f) and 1(k) to Chapter 96 provide as follows:
1.- This Chapter does not cover:
****
(f) Articles of chapter 90;
****
(k) Articles of chapter 94 (for example, furniture) 2 [.]
The General Explanatory Note to Chapter 96 provides, in pertinent part, as
follows:
2 Note 1(m) to Chapter 94 similarly excludes “monopods, bipods, tripods and similar articles (heading
96.20).”
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This heading covers monopods, bipods, tripods and similar articles, which are used as
support for cameras, video cameras, precision instruments, etc., to reduce random
movements. They may be extendable and are usually portable and may be equipped with
a quick release device or head for easy mounting and release of the apparatus or
instrument they support. These articles can be made of any material, e.g., wood,
aluminum, carbon or a combination thereof.
A monopod is a one-legged support, sometimes called a “unipod”. A bipod is a two-legged
support for providing stability along two axes of motion. A tripod is a three-legged stand,
which provides significant stability for the device it supports.
For the purpose of this heading, the expression “similar articles” refers to devices with four
or more legs, which have the same function as monopods, bipods and tripods in reducing
random movements.
You suggest classification of the instant merchandise in heading 9006, HTSUS, as
parts and accessories of photographic (other than cinematographic) cameras;
photographic flashlight apparatus and flashbulbs other than discharge lamps of heading
8539.
The user’s manual and other advertising material provided indicate that the
Colpocamera is a sophisticated digital camera for diagnostic use 3. The Colpocamera
uses memory cards and flash memory for purposes of image recording and retention as
opposed to photographic film.
The subheading that you have suggested provides for parts and accessories for
film cameras but not for digital cameras. See NY N267989, dated September 22, 2015.
It should be noted that “[p]hotographic and cinematographic cameras of Chapter 90
expose images onto photographic film of Chapter 37.”4 Since the Colpocamera does not
expose images onto photographic film but rather uses memory cards and flash memory
for purposes of image capture and retention, the Colpocamera is not a camera that falls
to be classified under Chapter 90 of the HTSUS. As such, the subject merchandise is
precluded from being classified as a part or an accessory under heading 9006, HTSUS.
Finally, Chapter 90 Note 1(l), HTSUS, plainly states that the chapter does not cover
monopods, bipods, tripods or similar articles of heading 9620, HTSUS.
The ENs to heading 9620, HTSUS, indicate that the heading includes “monopods,
bipods, tripods and similar articles, which are used as support for cameras, video
cameras, precision instruments, etc., to reduce random movements.” The terms
“monopod, bipod, and tripod” are defined in online lexicographic sources as follows:
Merriam-Webster (Last visited September 16, 2026): Monopod - a one-legged support (as for a
camera); Bipod - a 2-legged support; Tripod - a three-legged stand (as for a camera)
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See footnote 1, supra.
4 EN 85.25 (B) Television Cameras, Digital Cameras and Video Camera Recorders. See also the EN to
heading 9006, HTSUS: “photographic cameras are those in which the exposure of a chemical based film
(e.g., silver halide), plate or paper to the image or light from the camera’s optical system causes a
chemical change to the film, plate or paper. Further processing is required to create a viewable image.”
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Collins Dictionary (Last visited September 16, 2026): Monopod - a single-legged support used to
steady a hand-held camera; Bipod - a two-legged support; Tripod - A tripod is a stand with three
legs that is used to support something such as a camera or a telescope.
The Casio CST-100M colposcopy camera stand is a “cincopod,” i.e., a stand with
five legs, enhanced with casters with stoppers and a moveable arm to which the
colposcopy camera can be mounted. There is an adapter on the stand which reduces
random movements of the camera. Online marketing information states that the Casio
CST-100M camera stand is “designed with ultimate stability in mind,” adding that the
“stand allows the camera to be smoothly moved to the position you want to observe with
your arms free and then fixed in position [emphasis added].” The casters with
stoppers allow maneuverability of the stand and when “locked” keep the camera stand
stationary in the preferred position. Thus, the CST-100M camera stand is designed for
stability, maneuverability and the prevention of unintended, random movements.
Prior rulings have classified articles similar to monopods, bipods and tripods
under heading 9620, HTSUS, which are used to support cameras and other items. See
NY N328173, dated October 12, 2022 (classifying an aluminum tripod for studio lights)
and NY N317961, dated March 16, 2021 (classifying aluminum tripods for podcasts).
Based on the design and function of the CST-100M camera stand, the instant
merchandise is classifiable under subheading 9620.00.70, HTSUS.
HOLDING:
By operation of GRI 1, the Casio Colpocamera Stand, Model CST 100-M, is
classified under 9620.00.70, HTSUS, which provides for “Monopods, bipods, tripods and
similar articles: Other: Of aluminum.” The column 1 rate of duty is 2.5% ad valorem.
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 on the World
Wide Web at https://hts.usitc.gov/current.
A copy of this ruling letter should be attached to the entry documents filed at the
time the goods are entered. If the documents have been filed without a copy, this ruling
should be brought to the attention of the CBP officer handling the transaction.
Sincerely,
Andrew M. Langreich, Chief
Chemicals, Petroleum, Metals and
Miscellaneous Articles Branch
cc: NIS 135 and NIS 463
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