CLA-2-85:OT:RR:NC:N1:108
Mr. John Whitson
Costco Wholesale Corporation
999 Lake Drive
Issaquah, WA 98027
RE: The tariff classification of a Spy Wi-Fi Robot from China.
Dear Mr. Whitson:
In your letter dated July 14, 2008, you requested a tariff classification ruling. The sample which you submitted is being returned as requested.
The item in question, which is referred to as the ”Erector Spykee Spy Wi-Fi Robot,” is a composite good that consists of a CCTV camera, a Voice over Internet Protocol (VoIP) phone, a mobile MP3 player, and a robot erector set. Once the erector set is built into a robot (Spykee), it can move, observe, hear, speak, and take real time pictures with video and with sound effects. In addition, Spykee’s camera, microphone and Wi-Fi allow you to use your PC to keep control of this mobile CCTV robot from anywhere in the world. This CCTV robot is compatible with Skype software, which allows you to use Spykee as a webcam and talk to friends over the Internet or play your MP3 music through its speaker. Further, Spykee has no inbuilt recording capabilities.
Spykee can also be used as a video surveillance device. With its inbuilt motion detector, Spykee can detect movements and automatically capture an image in real time and sends the video to you via email. This sensor can also activate an alarm. Furthermore, when the batteries are low, Spykee automatically goes back to the docking station to recharge, without any help from a human. It is the opinion of this office that the CCTV camera imparts the essential character of this composite good.
The applicable subheading for the Erector Spykee Spy Wi-Fi Robot will be 8525.80.30, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Transmission apparatus for radio-broadcasting or television, whether or not incorporating reception apparatus or sound recording or reproducing apparatus; television cameras, digital cameras and video camera recorders: Television cameras, digital cameras and video camera recorders: Television cameras: Other. The rate of duty will be 2.1 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