Tariff NOS.: 9002.20.4000; 9001.90.9000
Ms. Veronica E. Hernandez
Attorney in Fact
Airport Customs Service, Inc.
5777 W. Century Blvd.
Los Angeles, CA 90045-5632
RE: The tariff classification of glass filters from Great Britain
Dear Ms. Hernandez:
In your letter dated June 19, 2015 you request a tariff classification ruling on glass filters on
behalf of Lee Filters USA. Three samples were furnished with your letter and are being returned to you as requested.
The polarizing filter, item PLC105, is in the form of a circular glass element with a diameter of 105 mm. It is mounted in a ring that fits to the front of a filter holder. This filter can be used with digital and film cameras and is suited for landscape photography. According to your letter, the glass element has been ground and polished and then coated.
The Big Stopper filter, item BSND/LSND, is in the form of a square glass element. It is designed for extending exposure times. It has the effect of allowing anything that is moving in the image to become blurred or ghost like. According to your letter, the Big Stopper is ground and polished, and then coated. You suggest that the Big Stopper filter is classified under subheading 9001.90.4000, Harmonized Tariff Schedule of the United States (HTSUS) which provides for Other: Lenses. The Big Stopper filter is not classifiable as a lens, since it is a filter.
The unmounted polarizing filter, item PLC, is designed to slot into a filter holder for use on a camera. It is composed of a polarizing sheet, sandwiched between two thin sheets of glass. It is in the form of a square and measures 100 mm by 100 mm and is 2 mm in thickness. .
The applicable subheading for the circular polarizing filter, item PLC105, will be 9002.20.4000, HTSUS, which provides for Lenses, prisms, mirrors and other optical elements, of any material mounted, being parts of or fitting for instruments or apparatus, other than such elements of glass not optically worked; parts and accessories thereof: Filters and parts and accessories thereof: Photographic. The rate of duty will be 2 percent ad valorem.
The applicable subheading for the Big Stopper filter, item BSND/LSND, will be 9001.90.9000, HTSUS, which provides for Lenses, prisms, mirrors and other optical elements, of any material, unmounted, other than such elements of glass not optically worked: Other: Other: Other. The rate of duty will be 2.9 percent ad valorem.
We require additional information in order to classify item PLC, the unmounted polarizing filter. Optical elements of glass, not optically worked by grinding and polishing, may be classified under heading 7014, HTSUS, if there is a process in manufacturing of the optical element which imparts optical properties to the element. Are the two sheets of glass incorporated in the polarizing filter optically worked by grinding and polishing the glass to achieve optical properties? If the sheets of glass are not ground and polished, what process of manufacture gives the polarizing filter its optical properties? For example, is the glass fire polished or molded in a manner that imparts optical properties? Please be specific in your reply.
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 Barbara Kiefer at [email protected].
Gwenn Klein Kirschner
National Commodity Specialist Division