Ms. Courtney Cabin
Phoenix Int’l Freight Services, Ltd.
855 IL Route 83
Bensenville, IL 60106-1219

RE: The tariff classification of a wireless back-up camera system from China.

Dear Ms. Cabin:

In your letter dated February 23, 2009, on behalf of Old World Industries, Inc., you requested a tariff classification ruling.

The subject merchandise, based on the submitted sample, is an automotive wireless back-up camera system, model PKC0RC, which consists of the following components: a TV camera, a seven-inch LCD color monitor with power cable, a transmitter box with power cable, an audio-video cable, a dashboard stand, a double-stick back base, and a user’s guide, as well as camera mounting accessories and monitor mounting belts, all of which will be imported in a retail-packed condition.

When the motor vehicle’s gear is shifted in the reverse position, the camera, which can be mounted onto the vehicle’s rear license plate, will wirelessly transmit in real time the images behind the vehicle to the monitor, which can be mounted onto the dashboard, the visor, or the headrest. It is stated that this back-up camera does not contain any recording capability.

You claim that this merchandise should be classified under subheading 8525.80.3010, 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: Other: Color.

This claim is based on a decision within NY Ruling Letter (NY) N025264, which ruled upon the classification of only a back-up camera, not a back-up camera with a monitor, and therefore, using this decision, within N025264, to classify the subject back-up camera system under subheading 8525.80.3010, HTSUS, would not apply. Further, Headquarters Ruling Letter (HQ) 957722 provides guidance in this matter for determining that the importance of the camera and the monitor units’ role in relation to the use of the system are equal, and therefore, based on General Rule of Interpretation 3(c), this system will be classified in the heading which occurs last in numerical order among those headings (in this instance, heading 8525, HTSUS, for the camera and heading 8528, HTSUS, for the monitor) which equally merit consideration.

The applicable subheading for this wireless back-up camera system will be under subheading 8528.59.2500, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Monitors and projectors, not incorporating television reception apparatus; reception apparatus for television, whether or not incorporating radio-broadcast receivers or sound or video recording or reproducing apparatus: Other monitors: Other: Color: With a flat panel screen: Other: With a video display diagonal not exceeding 34.29 cm. 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

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
National Commodity Specialist Division