CLA-2-85:OT:RR:NC:1:108
Mr. George R. Tuttle
Law Offices of George R. Tuttle
One Embarcadero Center, Suite 730
San Francisco, CA 94111
RE: The tariff classification of IP cameras from Taiwan.
Dear Mr. Tuttle:
In your letter dated May 5, 2009, on behalf of AverMedia Information, Inc., you requested a tariff classification ruling.
The merchandise under consideration is IP cameras that are referred to as the “AverMedia Image Platform Visual Presentation Cameras and Portable Document Cameras.” It is stated that these multifunctional cameras can capture images in real time as well as still images. Further, the information provided indicates that these cameras have inbuilt recording capability. It is important to note that these cameras cannot project an image onto a screen. These cameras require an electronic output device in order to perform this function. This office is of the opinion that neither the function of the television camera nor the function of the still image video camera predominates over the other to suggest that one capability constitutes the principal function.
At the time of importation these IP cameras are packaged for retail sale with a user’s manual, an installation CD-ROM, a power adapter, a power cord, an RCA cable (2X), an S-Video cable, a VGA cable, a USB cable, a dust cover, and an anti-glare screen. This combination would be considered a set for tariff classification purposes with the camera imparting the essential character.
The applicable subheading for these cameras will be 8525.80.4000, 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: Television cameras, digital cameras and video camera recorders: Digital still image video cameras. The rate of duty will be Free.
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 Lisa Cariello at (646) 733-3014.
Sincerely,
Robert B. Swierupski
Director
National Commodity Specialist Division