Mr. Daniel Cannistra
Crowell and Moring LLP
1001 Pennsylvania Ave.
Washington, DC 20004
RE: The tariff classification of a digital video management system from Taiwan
Dear Mr. Cannistra:
In your letter dated September 27, 2011, on behalf of Tyco Security Solutions, you requested a tariff classification ruling.
The merchandise in question is referred to as the “Intellex Ultra,” which is a composite machine that performs the following functions: video processing, video multiplexing, and video recording. This video processor/multiplexer/recorder operates on a Microsoft® operation Closed Circuit Television system, which is used in video surveillance applications. The Intellex Ultra system unscrambles and records the video signals received from video cameras and transmits these signals to users with access to the system. This system is not imported with video cameras or a monitor.
It has been determined that neither the video recording nor the video transmission function of this composite machine performs the principal function. Therefore, classification will be in accordance with General Rule of Interpretation 3(c), Harmonized Tariff Schedule of the United States (HTSUS), which states, in relevant part, that the merchandise shall be classified under the heading (in this instance, heading 8525, HTSUS) which occurs last in numerical order among those equally meriting consideration.
Consideration was given to classifying this merchandise in subheading 8525.60.2000, 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 incorporating reception apparatus: Other.” However, this merchandise is more specifically provided for elsewhere.
The applicable subheading for the Intellex Ultra 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.
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
National Commodity Specialist Division