CLA-2-90:OT:RR:NC:N2:212
Michael Forster
Advanced Input Devices
600 West Wilbur Avenue
Coeur d’Alene, ID 83815
RE: The tariff classification of aluminum camera parts from China
Dear Mr. Forster:
In your letter dated December 4, 2019, you requested a tariff classification ruling.
There are four items at issue that are described as aluminum parts exclusively for use with thermal image cameras. The first item is identified as part number 9200-24161 and specifically described as the main bracket. The bracket is made of stamped aluminum and shaped to support and mount the main printed circuit board assembly (PCBA) of the camera. The bracket is shaped to fit within the plastic housing of the camera and is attached by rear metal wings that are cast to specifically fit into pre-arranged slots.
The second item is identified by part number 9200-28499 and specifically described as a lens retention nut. This item is a machined aluminum threaded retention ring that is used to secure the thermal image camera’s lens in place. The retention nut mounts to the front of the camera and is attached to the core bracket within the camera.
The third item is identified by part number 9200-28500 and specifically described as the core mounting bracket. This bracket is a machined aluminum block mounted within the camera and used to support, retain, and align the thermal imaging core to the camera’s front end. The bracket is shaped to fit around the thermal imaging core within the main camera housing.
The fourth item is identified by part number 9200-28624 and specifically described as the bracket button PCB. This bracket is a machined aluminum item designed to provide support to the main PCBA and integrates additional support for the buttons that will be depressed by the camera’s user. The bracket is shaped to fit within the plastic housing of the camera and is attached by metal wings that fit within pre-arranged grooves. Further, this bracket functions as a heat sink for the PCBA.
In your request, you suggest that the correct classification for the subject aluminum parts is subheading 9013.90.7000, Harmonized Tariff Schedule of the United States (HTSUS). We agree.
It is the opinion of this office that, based upon the facts presented, the subject items are specifically designed and manufactured for use with thermal imaging cameras and have no other use outside of their function within the finished cameras. Further, these items are integral to the form and function of the finished thermal image camera. As the thermal imaging cameras do not work in visible light, they are correctly classified under heading 9013, HTSUS. Therefore, items determined to be parts for use exclusively with these items can be classified under the parts provision dictated by the terms of heading 9013, HTSUS.
The applicable subheading for part numbers 9200-24161, 9200-28499, 9200-28500, and 9200-28624 will be 9013.90.7000, HTSUS, which provides for “Liquid crystal devices not constituting articles provided for more specifically in other headings; lasers, other than laser diodes; other optical appliances and instruments, not specified or included elsewhere in this chapter; parts and accessories thereof: Parts and accessories: Other: Other parts and accessories, other than for telescopic sights for fitting to arms or for periscopes.” The general rate of duty will be free.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 9013.90.7000, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.03, in addition to subheading 9013.90.7000, HTSUS, listed above.
The HTSUS is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background information regarding the Section 301 trade remedy, you may refer to the relevant parts of the USTR and CBP websites, which are available at:
https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions https://www.cbp.gov/trade/remedies/301-certain-products-china
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 the 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 Luke LePage at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division