CLA-2-85:OT:RR:NC:N2:208
Mr. Ralph Natale
American Shipping Co, Inc.
250 Moonachie Road
Moonachie, NJ 07074
RE: The tariff classification of a doorbell camera and chime from China
Dear Mr. Natale:
In your letter dated November 28, 2017, on behalf of Digital Peripheral Solutions, Inc., you requested a tariff classification ruling.
The merchandise under consideration is the Q-See Wi-Fi Doorbell Camera and Chime, model QCA8081B-N, which is primarily used for video surveillance. This composite machine contains a built-in microphone, a night vision camera with a 140 degree wide angle lens, chimes, 2-way talk, and a motion detector. The camera can capture “real time” video images and transmit them to a mobile device. The camera can also record the video images internally onto a micro SD card. Moreover, this merchandise will allow one to see who is at the door, as well as communicate with the person at the door, from anywhere by use of a mobile application. It is the opinion of this office, that the surveillance camera provides the principal function of this composite machine.
In your submission you request that this merchandise should be classified as other apparatus for transmission or reception of voice, images or other data, including apparatus for communication in a wired or wireless. However, this fucniton is secondary to that of the security camera function and as such would not provide the principal function to this home security device.
The applicable subheading for the Q-See Wi-Fi Doorbell Camera and Chime 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 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 https://hts.usitc.gov/current.
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 [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division