CLA-2-85: RR: NC: 1:108 M84682

Ms. Lucy Richardson
Sony
1 Sony Drive
Park Ridge, NJ 07656-8003

RE: The tariff classification of video recorder from Japan.

Dear Ms. Richardson:

In your letter dated June 23, 2006 you requested a tariff classification ruling.

The item in question, model number HDW-2000, is a video tape recorder used in professional broadcast facilities. The device records, on tape, video images and sound captured by a television camera and or other professional videotape recorder/players. This video tape recorder also employs a simple video editing function.

Legal Note 3 to Section XVI provides “That unless the context otherwise requires, composite machines designed for the purpose of performing two or more complementary functions or alternative functions are to be classified as if consisting only of that component or as being that machine which performs the principal function”.

It is the opinion of this office that this specific device is a composite machine in accordance with Legal Note 3. It is the opinion of this office that the principal function is that of video recording. The device is designed for use as such in a professional broadcasting capacity. Classification will be accordingly.

The applicable subheading for the video tape recorder, model number HDW-2000 will be 8521.10.6000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Video recording or reproducing apparatus, whether or not incorporating a video tuner: Magnetic tape-type: Color, cartridge or cassette type: Other. The rate of duty will be free.

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 Michael Contino at 646-733-3014.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division