Mr. Ying Hui Yuan
93 Rue Nationale
Boulogne Billancourt 92100

RE: The tariff classification of a video camera recorder integrated into an LED floodlight from China.

Dear Mr. Yuan:

In your letter dated August 3, 2016, you requested a tariff classification ruling.

The merchandise under consideration is referred to as the “Netatmo Presence,” which is a composite good that consists of an outdoor security camera integrated into an LED floodlight. This camera captures and records video onto a micro-SD card that is stored in the camera. Additionally, this camera, which can detect people, cars and animals, has infrared capability so that it can record video in the dark. Moreover, this camera can connect to the Internet via Wi-Fi and works with companion applications where the user can receive notifications, watch recorded videos, or control the light functions. This camera does not capture or record still images. It is the opinion of this office that the essential character of the “Netatmo Presence” is imparted by the video camera recorder function.

The applicable subheading for the Netamo Presence will be 8525.80.5050, 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: 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