CLA-2-85: RR: NC: 1:108 L82643

Ms. Irene Chan
T.H. Kelly Int’l Inc.
813 W. Arbor Vitae St., 2nd floor
Inglewood, CA 90301

RE: The tariff classification of digital video recorders and a wireless transmission device from Taiwan.

Dear Ms. Chan:

In your letter dated February 11, 2005 you requested a tariff classification ruling.

The items in question are digital video recorders and a wireless video transmission device. They are denoted as model numbers DV6010M, DV6010R and DWT100-G.

The digital video recorders (DV6010M, DV6010R) are specifically designed for use in vehicles for mobile surveillance digital video recording. They both incorporate an internal hard, with up to 80GB of storage, for recording with multiple recording modes. Each provides the user with a standard 10/100 BaseT Ethernet port for real time remote monitoring. They are each stand-alone devices providing video recording and playback in a non-PC embedded system.

The wireless transmission device (DWT100-G) allows the user to transmit real-time video signals over an expansive area. It is designed for use in vehicles providing for real time video transmission in a mobile surveillance system. It also incorporates a GPS receiver for linkage to GSM worldwide networks as well as a 10/100M Ethernet port. It can transmit live video through the GPRS network allowing the images to be viewed on any PC or cellular telephone.

The applicable subheading for the digital video recorders will be 8521.90.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for Video recording or reproducing apparatus, whether or not incorporating a video tuner: Other. The rate of duty will be free.

The applicable subheading for the wireless video transmission device will be 8525.10.3040, Harmonized Tariff Schedule of the United States (HTS), which provides for Transmission apparatus for radiotelephony, radiotelegraphy, radiobroadcasting or television, whether or not incorporating reception apparatus or sound recording or reproducing apparatus; television cameras; still image video cameras and other camera recorders; digital cameras: Transmission apparatus: Television: Other … Other. The rate of duty will be 1.8 percent ad valorem.

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 Michael Contino at 646-733-3014.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division