CLA-2-85:OT:RR:NC:N1:112
Mr. Kevin Gurr
VR Technology Limited
Unit 12. Blackhill Rd West
Holton Heath Industrial Estate
Poole, Dorset, BH16 6LE
United Kingdom
RE: The tariff classification of a submersible dive computer from the Untied Kingdom
Dear Mr. Gurr:
In your letter received on August 26, 2008, you requested a tariff classification ruling.
The item concerned is the VR3 submersible dive computer. This device measures approximately 3 inches x 3.5 inches x 1 inch. It has an aluminum housing which incorporates an LCD screen/panel, a dual button keypad, two RS232 serial communication ports, direct A/D line access, and a parallel port. Internally this device incorporates a Hitachi microcontroller/CPU. It has 256Kb of program memory, 8Kb of EEPROM, and 512KB of RAM.
This computer uses internally stored algorithms/programs to mathematically model the theoretical tissue compartments of the human body and their reaction to inert gas loading. After analyzing certain “dive” variables, such as the current water pressure, length of dive, air/gas mixture, this computer instructs the diver as to the proper way to ascend to the surface without getting decompression sickness (the bends). It directs the diver to their first decompression stop, and provides the amount of time they need to stay at that stop or depth, it then it directs the diver to their second stop and the length of time for that stop, it continues this until they reach the surface. This computer is also used as a data logger for pressure, time and temperature. This data, as well as other recorded dive data, can be viewed on the VR3 computer or downloaded to a PC. The VR3 will generally be imported with only the internal pressure and temperature sensors, but various other sensors could be attached to the device depending on the customer’s requirements. Electronic books can be downloaded to this computer from a PC using “DecoBooks” software and it also has a game playing capability. This computer can operate in English, French, German, Spanish, Italian, Polish or Russian.
The VR3 submersible dive computer has a customizable primary dive screen which allows the user to select the information they want access to. This computer can provide access to various dive related data such as decompression information, maximum depth so far, average depth of the dive, ambient temperature, time to surface information, current ceiling depth, current active gas information, battery information, a pre-dive check list, the time the diver can stay at the current depth before decompression, a graph which shows the track of the dive so far, a graph which shows a projected profile of the ascent the diver should make if he ascends now, etc. This unit can be worn by a diver, attached to their equipment or carried.
The applicable subheading for the VR3 submersible dive computer will be 8543.70.9650, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electrical machines and apparatus…: Other machines and apparatus: Other: Other: Other: Other.” The rate of duty will be 2.6%.
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 Steve Pollichino at (646) 733-3008.
Sincerely,
Robert B. Swierupski
Director
National Commodity Specialist Division