CLA-2-85:OT:RR:NC:N1:108
Mr. Steven Papier
Canary Connect Inc.
132 E. 43rd Street
Suite 552
New York, NY 10017
RE: The tariff classification of an HD camera security system from China
Dear Mr. Papier:
In your letter received in this office on August 1, 2014, you requested a tariff classification ruling.
The merchandise subject to this ruling request is the Canary security camera. The Canary is a complete security system, which contains an HD camera with a wide-angle lens and night-vision capability, along with built-in sensors capable of detecting changes in motion, temperature, humidity, and air quality. Moreover, this CMOS camera adapts to your home and sends intelligent notifications with HD video directly to your smartphone. Further, this camera does not permanently record video internally. It is the opinion of this office that the principal function of this composite machine is performed by the camera function.
In your submission, you request classification in subheading 8525.50.3040, 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: Transmission apparatus: Television: Other: Other: Other. However, the principal function of this system is that of a camera that captures images and converts them into an electronic signal that
is transmitted as a video image to a location outside the camera (in this case the smartphone) for viewing or remote recording, which is specifically provided for in subheading 8525.80.30, HTSUS.
The applicable subheading for the Canary security camera will be 8525.80.3010, 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: Other: Color. 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 [email protected].
Sincerely,
Gwenn Klein Kirschner
Director
National Commodity Specialist Division