CLA-2-85:OT:RR:NC:N2:208
Ms. Lili Liu
Netatmo
73 Rue de Sèvres
Boulogne-Billancourt, 92100
France
RE: The tariff classification of a smart video doorbell from China
Dear Ms. Liu:
In your letter dated August 24, 2020, you requested a tariff classification ruling.
The merchandise under consideration is the Netatmo Smart Video Doorbell. This composite machine consists of an HD camera, a Wi-Fi antenna, a microphone, a speaker, an accelerometer, and an infrared LED. The HD 1080p camera can capture “real-time” video images and transmit them to an application on a smartphone. In addition, this HD camera, which has a field of view of 160 degrees, can capture and record snapshots in JPEG format and video in MP4 format onto an internal micro SD card. Moreover, this Netatmo Smart Video Doorbell allows one to see and speak to visitors at their door through an application on their smartphone. It is the opinion of this office, that the HD camera performs the principal function of this composite machine.
The applicable subheading for the Netatmo Smart Video Doorbell 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.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under subheading 8525.80.4000, HTSUS, unless specifically excluded, are subject to an additional 7.5 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.15, in addition to subheading 8525.80.4000, HTSUS, listed above.
The HTSUS is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background information regarding the trade remedy initiated pursuant to Section 301 of the Trade Act of 1974, you may refer to the relevant parts of the USTR and CBP websites, which are available at https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and https://www.cbp.gov/trade/remedies/301-certain-products-china respectively.
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 the 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