CLA-2-85:OT:RR:E:NC:1:108
Mr. Caio L. de Freitas
Trade and Imports Manager
3Com Corp
350 Campus Drive
Marlborough, MA 01752
RE: The tariff classification of video encoders from China.
Dear Mr. de Freitas:
In your letter dated May 22, 2009, you requested a tariff classification ruling.
The merchandise subject to this ruling is two types of video encoders. They are identified within your submission as Item numbers EC2004-HF and H3C EC1001-HF.
The EC2004-HF video encoder can implement audio/video input of monitored signals, digitize analog audio/video signals (including audio/video source signals of microphone and video camera) and provide code compression. In addition, the EC2004-HF can encapsulate the audio/video codes into IP packets and transmit them to a designated destination address through networks. It is aimed at professional monitoring and security environments that require video images and applications of high quality in government office, police stations, airports, and undergrounds that require real-time monitoring. The encoder provides diversified network interfaces and protocols, including an Ethernet electrical port, uni-cast, and multi-cast.
The H3C EC1001-HF video encoder integrates audio/video code compression and data transmission and is suitable for remote real-time video monitoring and far-end live voice transmission monitoring. The H3C EC1001-HF is widely applied in environments such as security, traffic, and electric power that require real-time monitoring. It adopts an embedded operating system, supports multiple image compression formats (including H.264 and MJPEG), a resolution of 720 x 576 pixels, and a transmission bandwidth of up to four Mbps, and provides high definition (HD) images of DVD quality. Adopting all-IP network transmission, the H3C EC1001-HF supports point-to-multipoint transmission (multicast) and allows for flexible networking and better scalability. By integrating the iSCSI and network attached storage (NAS) client modules, the H3C EC1001-HF can transmit audio/video data on networks through the iSCSI or network file system (NFS) protocol and save the data to the IP network storage system (IP SAN or NAS) to implement centralized audio/video data storage and management. It contains an Ethernet port, small form factor pluggable (SFP) port, RS485 serial port, and RS232 serial port and is suitable for various networking environments.
You suggested Harmonized Tariff Schedule (HTS) subheading 8517.69.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Other apparatus for transmission or reception of voice, images or other data, including apparatus for communication in a wired or wireless network (such as a local or wide are network), other than transmission or reception apparatus of heading 8443, 8525, 8527 or 8528: Other. However, the principal function of these video encoders falls within heading 8525, HTSUS. Therefore, classification of Item numbers EC204-HF and H3C EC1001-HF, under heading 8517, HTSUS, is inapplicable. These video encoders are considered television transmission apparatus classifiable within heading 8525, HTSUS.
The applicable subheading for the video encoders (EC2004-HF and H3C EC1001-HF) will be 8525.50.30, 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: Transmission apparatus: Television: Other. The general duty rate will be 1.8 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 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