CLA-2-85:OT:RR:NC:N2:208
Mr. Ari Roisman
Glide Inc.
16 N San Mateo Dr.
San Mateo, CA 94401
RE: The tariff classification of a Wristcam from China
Dear Mr. Roisman:
In your letter dated November 1, 2018, you requested a tariff classification ruling.
The merchandise under consideration is referred to as the “Wristcam,” which is a smartwatch strap with two HD camera modules, an SoC processor, an 8GB memory chip, a Bluetooth/Wi-Fi module, a gyro, microphones, and a battery. This wearable digital camera, which is compatible with the Apple Watch, can capture and record both photos (still images) and videos (moving images). Moreover, the cameras record still images in JPG and moving images in MP4 formats and stores them on the 8GB internal storage. It is the opinion of this office, that the cameras impart the essential character of this composite article.
The applicable subheading for the Wristcam will be 8525.80.4000, 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: Digital still image video cameras. 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 https://hts.usitc.gov/current.
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,
Steven A. Mack
Director
National Commodity Specialist Division