CLA-2-85:OT:RR:NC:N2:220
Kelly Lee
Sung Oak Park DBA Ace E-Custom
2910 E. Pacific Commerce Drive
Compton, CA 90221
RE: The tariff classification of an electrical controller from China
Dear Ms. Lee:
In your letter dated August 17, 2020 you requested a tariff classification ruling on behalf of your client, Hanwha Techwin America Inc.
The merchandise under consideration is identified as the PTZ/DVR System Controller Model SPC-2010 (Controller), which is described as a video system controller. The Controller controller has multiple keypad bars, a joystick, a liquid crystal display, and a jog shuttle wheel (for video playback). On the rear of the Controller is a terminal block where devices, such as cameras, are connected in order to control their functions via RS-485/422 communication protocols. In your request, you state that the Controller is principally used to control camera movement, to include remote camera zoom, pan, and camera iris, as well as controlling the functions of an attached receiver/digital video recorder.
In your letter, you suggest the Controller should be classified under subheading 8529.90.8100, Harmonized Tariff Schedule of the United States (HTSUS). We disagree. This merchandise is not a part suitable for use solely or principally with a camera of heading 8525, HTSUS. Additionally, it is specially provided for elsewhere in the tariff; therefore, heading 8529, HTSUS, is not applicable.
The applicable subheading for the PTZ/DVR System Controller Model SPC-2010 will be 8537.10.9170, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Boards, panels, consoles, desks, cabinets and other bases, equipped with two or more apparatus of 8535 or 8536, for electric control or the distribution of electricity…: For a voltage not exceeding 1,000 V: Other: Other: Other”. The general rate of duty will be 2.7 percent ad valorem.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 8537.10.9170, 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 8537.10.9170, 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 trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, 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 Karl Moosbrugger at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division