NY 864039

JUN 24 1991


CLA-2-90:S:N:N1:114 864039

Ms. Debra L. Micklis
C-Air International, Inc.
11222 S. La Cienega Boulevard
Suite 470
Inglewood, California 90304

RE: The tariff classification of Tele-cine Converters from Taiwan

Dear Ms. Micklis:

In your letter dated May 21, 1991, on behalf of T. T. Systems Corporation, you requested a tariff classification ruling. The Tele-cine Converter, also referred to in the descriptive literature as a Video-cine Converter, is designated as Model 610. It is an optical device that allows the operator to transfer 8mm and 16mm movie film and slides to video tape.

The Model 610 Tele-cine Converter does not contain a recording device. It is a housing, made of plastic, with a clear window which is approximately 2 inches by 1 3/4 inches in size and a built-in screen which is approximately 3 3/4 inches by 3 inches in size. Located inside the metal housing, on an angle, is a mirror. In use, the movie or slide projector is placed so that the image is directed into the clear window located on the side of the Tele-cine Converter. The mirror inside the housing directs the image from the window to the mini screen. The user positions a video camera so that the image on the mini screen is in focus. The video camera is used to record the images that appear on the mini screen onto the video tape.

The applicable subheading for the Tele-cine Converter will be 9013.80.6000, Harmonized Tariff Schedule of the United States (HTS), which provides for other optical devices, appliances and instruments. The rate of duty will be 9 percent ad valorem.

This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177).

A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction.

Sincerely,

Jean F. Maguire
Area Director
New York Seaport