Mr. Bryan Zhou
51 Stouts Lane
Monmouth Junction, NJ 08852
RE: The tariff classification of apparatuses for a video surveillance system from China.
Dear Mr. Zhou:
In your letter dated May 14, 2007, you requested a tariff classification ruling.
You requested a binding classification ruling for a PTZ Dome Camera, a Matrix Switcher, a Video Mux Transmission System, a Digital Video Recorder (DVR), and a PTZ Dome Controller Keyboard. All the devices in question are products for a video surveillance system, which provides security to corporations, educational facilities, government institutions and many other public and private facilities. The first apparatus in question is referred to as the “PTZ Dome Camera”, the V1740 series. This closed-circuit television (CCTV) camera captures live images in real time. In addition, it is a high-speed in-ceiling, outdoor PTZ dome camera with multi-protocol capabilities. This camera is compatible with control site equipment from Infinova, such as the V2109 and V2117 keyboards and Infinova matrix switcher, as well as equipment from third party manufacturers. The Infinova dome cameras have recording capabilities.
The applicable subheading for the PTZ dome camera will be 8525.80.30, 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: Television cameras: Other. The rate of duty will be 2.1 percent ad valorem.
The second device in question is referred to as the “Video Matrix Switcher”, the V2020 series. It is a network-able video matrix switcher used in surveillance systems that have a high camera and monitor count combination. This device further transmits the video signal to a viewing and/or recording device such as a monitor or a DVR. In addition, it utilizes microprocessor technology to provide automated electronic surveillance or to allow a single user to control an entire CCTV system, which reaches to 240 video inputs by 32 video outputs.
The next device is referred to as the “2 Video Mux Transmission System”, the N3642 series. This system has the capability to transmit two frequency modulated (FM) video channels over one multi-mode optical fiber. Basically, it converts electronic video signals to optical signals and transmits them over one fiber.
In your original letter, you express the opinion that the video matrix switcher and the video mux transmission system are properly classified under subheading 8525.60.20, Harmonized Tariff Schedule of the United States (HTSUS), which provides for transmission apparatus incorporating reception apparatus. In accordance with prior Customs’ decisions (HQ 962973, HQ 95497, HQ 087724, HQ 088746, HQ 955309, etc.), these apparatuses were found to be more specifically classified under transmission apparatus for television, thereby precluding consideration of classification under subheading 8525.60.20, HTSUS.
The applicable subheading for the video matrix switcher and the video mux transmission system will be 8525.50.30, 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. The rate of duty will be 1.8 percent ad valorem.
You also inquired about the classification of a digital video recorder (DVR), the V3010 series. This DVR functions as both a digital video recorder and a digital video server. It is designed for use in the video surveillance industry. This device digitizes and records live video images from surveillance cameras onto its hard drive.
The applicable subheading for the digital video recorder will be 8521.90.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Video recording or reproducing apparatus, whether or not incorporating a video tuner: Other. The rate of duty will be Free.
The last device in question is referred to as the “PTZ Dome Controller/Keyboard”, the V2109 series. It is a stand-alone device that is compatible with all Infinova PTZ and fixed camera systems. This keyboard is specifically designed for the configuration and the programming of the video matrix switcher, the PTZ dome camera, and the DVR. In addition, it can be connected to the video matrix switcher, the PTZ dome camera and the DVR by means of a cable. The V2109 does not contain memory for the controls, but can control up to 16 cameras without the need for matrix switchers or DVRs.
In your original classification request, you contended that the PTZ dome controller/keyboard should be classified in subheading 8471.60.20, Harmonized Tariff Schedule of the United States (HTSUS), which provided for Keyboards for automatic data processing machines not entered with the rest of a system. However, this keyboard is not designed for automatic data processing (ADP) machines; therefore, it is precluded from heading 8471 by virtue of Chapter 84, Note 5 (E).
The applicable subheading for the PTZ dome controller keyboard will be 8537.10.9070, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Boards, panels, consoles, desks, cabinets, etc., equipped with apparatus for electric control: For a voltage not exceeding 1,000 V: Other: Other: Other. The rate of duty will be 2.7 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 646-733-3014.
Robert B. Swierupski