CLA-2-90:OT:RR:NC:N4:414
Ms. Vanessa Couturier
HGH Infrared Systems, Inc.
One Broadway, 14th Floor
Cambridge, MA 02142
RE: The tariff classification of the IR Revolution 360 from France
Dear Ms. Couturier:
In your letter dated November 2, 2010 you requested a tariff classification ruling.
The IR Revolution 360 is an infrared vision system that enables panoramic surveillance over 360 degrees. The IR Revolution 360 sensor head continuously rotates at one round per second. The extremely wide field of view and fast rotation ensure that no event is missed in large areas in total darkness, smoke and inclement weather.
The IR Revolution 360 is described in your letter as a type of line scan camera working in the thermal infrared spectral band. A long wave infrared lens collects and focuses the incoming infrared radiation onto a long wave infrared staggered linear array detector. The lens is comprised of several individual lenses made of germanium, which together with the long wave infrared staggered linear array detector, gives a vertical linear field of view of 5 degrees, 10 degrees or 20 degrees, depending on the model. The continuously rotating sensor head enables the device to make a thermal infrared image of a 360 degree scene in the horizontal direction.
The IR Revolution 360 comprises the sensor head, a ten meter long cable for signal transmission between the sensor head and the PC, the IR Revolution 360 Cyclops software and a PC. The PC is separately imported. The applications for the device include perimeter security at ports and airports, intrusion detection, day and night panoramic surveillance, and coastal and border surveillance. The principal function of the IR Revolution 360 is as a thermal infrared 360 degree wide area surveillance system which has the ability to simultaneously to detect several intruders by their heat and to visualize these intruders with different types of views.
According to your letter, the IR Revolution 360’s sensor head differs from typical television cameras used for surveillance on the following points: the detector is a thermal infrared staggered linear array, not a visible 2-Dimensional CCD array, the format is a different format from a video image format, the horizontal field of view is 360 degrees and the data refresh rate differs from that of a video image rate. The sensor head is sensitive to thermal infrared radiation, not to visible light or to short wave infrared light. In addition, the sensor head output signal has a specific raw digital format, not a standard video format such as RS-170 or NTSC, and the sensor head cannot be directly attached to a video TV monitor or to a video recorder.
The applicable subheading for the IR Revolution 360 will be 9013.80.9000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other optical appliances and instruments, not specified or included elsewhere in this chapter; other devices, appliances and instruments, other. The rate of duty will be 4.5 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 Barbara Kiefer at (646) 733-3019.
Sincerely,
Robert B. Swierupski
Director
National Commodity Specialist Division