Mr. Kenny Choi
1525 McCarthy Blvd
Suite 1008
Milpitas, CA 95035

RE: The tariff classification of a camera

Dear Mr. Choi:

In your letter dated July 1, 2016, on behalf of Matterport, you requested a tariff classification ruling.

The merchandise under consideration is the Matterport Pro Camera which creates immersive 3D images. This camera consists of an array of three sensors, including a CMOS sensor, mounted on a motor that rotates the camera 360 degrees to capture the RGB and depth data needed to create a 3D replica of a location. Moreover, the Matterport Pro transmits still images to an iPad (not included) for remote viewing and recording. This camera cannot capture or transmit a moving or video image. At the time of importation, this camera is package for retail sale with a wall charger and compatible wall cord. It is the opinion of this office that the essential character of this set is imparted by the Matterport Pro Camera. In your request, you suggest classification in subheading 8525.80.4000, Harmonized Tariff Schedule of the United States (HTSUS), which in pertinent part, provides for digital still image video cameras. However, this camera cannot capture and record both still and video images. Therefore, classification is this subheading is not applicable. The applicable subheading for the Matterport Pro Camera will be 8525.80.5050, 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: Other: Other. The rate of duty will be 1.5 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 the 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


Steven A. Mack
National Commodity Specialist Division