Mr. Shawn Glover
UPS Trade Management Services, Inc.
2031 S. Centennial Ave.
Aiken, SC 29803

RE: The tariff classification of event recorders from China

Dear Mr. Glover:

In your letter dated October 28, 2016, on behalf of Lytx, Inc., you requested a tariff classification ruling.

The merchandise under consideration is referred to as “Event Recorders,” part numbers DC3P, SV2 and SF1. Each of these composite machines feature a video camera recorder, a microphone, a GPS, an accelerometer, a modem, and can be enabled to detect fuel and engine data. Moreover, the subject event recorders detect abnormal driving events such as, sudden stopping, swerving, collisions, etc., which trigger the devices to start capturing video and data. Further, these event recorders track, record, and transmit video and related data concerning risky driving events. The cameras in these event recorders capture and record moving images, but cannot record still images. Additionally, the cameras capture images in “real time” and transmit them to a location outside the camera for remote view or recording. It is the opinion of this office that the principal function of this composite machine is performed by the digital camera recorder. In your request you suggest classification in subheading 8526.91.0040, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Radar apparatus, radio navigational aid apparatus and radio remote control apparatus: Other: Radio navigational aid apparatus: Other. However, the principal function of this device is not that of radio navigational aid apparatus; therefore, classification in subheading 8526.91.0040, HTSUS, is not applicable.

The applicable subheading for the subject event recorders 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 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