CLA-2-90:OT:RR:NC:N1:105
Shane O’Sullivan
Os Big Picture Productions Limited
18 Merrion Row
Dublin
Ireland
RE: The tariff classification of a smart camera from China
Dear Mr. O’Sullivan:
In your letter dated August 8, 2025, you requested a tariff classification ruling. Descriptive literature was
provided for review.
The item under consideration is described as the VisionR Scout artificial intelligence (AI) Camera Kit, which
contains a standard USB webcam, a main processing unit with 12v power supply, and two antennas (one for
Wi-Fi and one for cellular network). The USB webcam is a 2 inch by 2 inch black cube that comes with a
small hinge for mounting to the ceiling. The main processing unit is a credit card sized black box that
contains a standardized electrical board with either a Hailo 8 Chip or an Intel Movidius central processing
unit (CPU). It also contains a 4G cellular module, a Wi-Fi module, a USB port, a debug port, and a power
port. The sensors and other supporting devices assess an image of an individual in order to note certain
characteristics of that individual. The Scout Camera analyzes live shopper characteristics in-store and returns
anonymized meta data to VisionR for processing. The kit provides information on daily store footfall,
estimated demographic profiles of store traffic, and heatmaps and cold zones in-store.
The information gathered includes characteristics (estimated age range and estimated gender), body
movements (shopper movement, shopper engagement with point of interest), and facial movements (facial
roll, facial yaw, facial pitch, and head and eye positioning). Images taken from a VisionR device are
processed in real-time, on the device using the latest machine learning embedded chips and do not leave the
device. Images are only stored in temporary memory, one image at a time, and then each image is
permanently deleted as the next one is assessed.
Similar to the Aurora V2, in New York Ruling N321590 (dated October 6, 2021), we consider this
merchandise to be a composite machine, which uses the camera to provide video, the onboard analytics to
provide measurements and cellular/Wi-Fi modules to transmit data. Since, a principal function cannot be
determined for this composite machine, General Explanatory Note (VI) to Section XVI directs us to apply
General Interpretative Rule 3 (c). General Interpretative Rule 3 (c) provides that goods shall be classified
under the heading which occurs last in numerical order among those (heading 8517, transmit data; heading
8525, video; and heading 9031, providing measurements) which equally merit consideration. Based on the
above, classification of this device will be under heading 9031, Harmonized Tariff Schedule of the United
States (HTSUS).
The applicable subheading for the VisionR Scout AI Camera Kit will be 9031.49.9000, HTSUS, which
provides for “Measuring or checking instruments, appliances and machines, not specified or included
elsewhere in this chapter; profile projectors; parts and accessories thereof: Other optical instruments and
appliances: Other: Other.” The general rate of duty will be free.
Effective March 4, 2025, pursuant to U.S. Note 2(u) to Subchapter III, Chapter 99, all products of China and
Hong Kong as provided by heading 9903.01.24, HTSUS, other than products classifiable under headings
9903.01.21, 9903.01.22, and 9903.01.23, HTSUS, will be subject to an additional 20 percent ad valorem rate
of duty. At the time of entry, you must report the applicable Chapter 99 heading, i.e., 9903.01.24, in addition
to subheading 9031.49.9000, HTSUS, listed above.
Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise must
be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the
Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time products from China will be
subject to an additional 10 percent ad valorem rate of duty. At the time of entry, you must report the Chapter
99 heading applicable to your product classification, i.e. 9903.01.25, in addition to subheading 9031.49.9000,
HTSUS, listed above.
Pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, products of China classified under
subheading 9031.49.9000, HTSUS, unless specifically excluded, are subject to an additional 25 percent ad
valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading 9903.88.01 in
addition to subheading 9031.49.9000, 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, including
information on exclusions and their effective dates, 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.
The tariffs and additional duties cited above are current as of this ruling’s issuance. 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 at https://hts.usitc.gov/.
The holding set forth above applies only to the specific factual situation and merchandise description as
identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations
(CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the
information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and
complete in every material respect. In the event that the facts are modified in any way, or if the goods do not
conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and
Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2.
Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic
verification by CBP.
This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection
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, please contact
National Import Specialist Jason Christie at [email protected].
Sincerely,
(for)
James Forkan
Acting Director
National Commodity Specialist Division