Mr. Andrew Donaldson
Perceptron Inc.
47827 Halyard Drive
Plymouth, MI 48170

RE: The tariff classification of a video inspection system from China

Dear Mr. Donaldson:

In your letter dated July 11, 2012, you requested a tariff classification ruling.

The merchandise in question is referred to as the “Video Scope, Digital, Wireless,” part number BK8000, which is used for automotive and industrial video inspection. The BK8000 is a composite machine that consists of a battery powered handle attached to a television type camera that transmits video images using wireless 802.11 protocols to a battery powered LCD monitor, which is connected to the camera via a cable. The LCD monitor has a diagonal screen size of 4.3 inches and contains inbuilt internal recording capability.

As per Legal Note 3 to Section XVI, composite machines are classified according to their principal function. However, no single component can be viewed as performing the principal function of this composite machine. Neither the camera nor the monitor can function independently of one another to achieve the inspection function. As a result, both the camera and the monitor contribute equally to the system’s function. Therefore, classification of this machine will be in accordance with Rule 3 (c) of the General Rules for the Interpretation of the Harmonized System. General Interpretative Rule 3 (c) provides that goods shall be classified in the heading which occurs last in numerical order among those (heading 8525, the camera, and heading 8528, the monitor) which equally merit consideration.

The applicable subheading for this video inspection device will be 8528.59.1500, 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: Incorporating video recording or reproducing apparatus: 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.


Thomas J. Russo
National Commodity Specialist Division