CLA-2-85:OT:RR:NC:N1:108
Mr. Joon Rhee
Frontier Logistics Services
1700 N. Alameda Street
Compton, CA 90222
RE: The tariff classification of a CCTV surveillance system from Korea and China
Dear Mr. Rhee:
In your letter dated September 3, 2010, on behalf of Samsung Opto Electronics America (dba Samsung Techwin America), you requested a tariff classification ruling.
The merchandise under consideration is a CCTV surveillance system, which consists of four surveillance cameras, a 21inch LCD monitor that incorporates a DVR, a mouse, and a remote control. The individual components of this surveillance system function in a cohesive, seamless manner to complete the task of video surveillance. These components are not fitted together to form a whole. Rather, they are separately presented components which function together as a security surveillance system.
While the system does consist of individual components, interconnected by electric cables or other devices, the components do not “contribute together to a clearly defined function covered by one of the headings in chapter 84 or chapter 85.” However, this system is composed of articles that meet the criteria to be considered a set for tariff classification purposes.
Consideration was given to classifying this set in subheading 8525.80.3010, HTSUS, which provides for other television cameras, as requested. However, Customs and Border Protection has consistently determined in prior rulings that no single component can be viewed as imparting the essential character of similar security systems incorporating video monitors, a recording device, and security cameras. Therefore, based on this reasoning, these types of systems have been currently classified according to General Rule of Interpretation 3(c), in the heading that appears last in numerical order among those equally meriting consideration, which in this case is heading 8528, HTSUS.
The applicable subheading for this surveillance system will be 8528.59.2000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "Monitors and projectors, not incorporating television reception apparatus; reception apparatus for television, whether or not incorporating radio-broadcast receivers or sound or video recording or reproducing apparatus:….". The rate of duty will be 3.9 percent 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 World Wide Web at http://www.usitc.gov/tata/hts/.
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 Lisa Cariello at (646) 733-3014.
Sincerely,
Robert B. Swierupski
Director
National Commodity Specialist Division