CLA-2-85:OT:RR:NC:N2:208

Kelly Danks
ICAT Logistics Inc.
6805 Douglas Legum Dr.
Elkridge, MD 21075

RE: The tariff classification of camera parts and the country of origin of camera parts imported separately and imported together as a video scope camera

Dear Ms. Danks:

In your letter dated April 17, 2026, on behalf of your client, Inspectron Inc., you requested a tariff classification and country of origin determination ruling.

The merchandise under consideration is a handheld unit (Part 1) and an imager cable (Part 2), which are replacement parts for the BK3000-55A video inspection scope and are imported separately. The handheld unit acts as the control and display module, and the imager cable contains the image capture components. Both items are necessary for the video scope camera to function properly. As per the latest information provided, the handheld unit contains a display screen that displays still images but cannot process or convert video images. The imager cable contains a CMOS sensor but does not convert or process image data. Moreover, the handheld unit and the imager cable are both integral, constituent, or component parts of the finished video scope.

You also requested a ruling on the complete video scope, model BK3000-55A, which consists of the handheld unit and the imager cable imported packaged together. The classification of this scenario was previously ruled on in ruling number NY N339004.

In your original submission, you suggested that the handheld unit is classified under subheading 8528.52.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for monitors that directly connect to and are designed for use with an automatic data processing (ADP) machine of heading 8471. However, this handheld unit does not directly connect to nor is designed for use with an ADP machine. Additionally, based on the information provided, as imported it is not a complete monitor. Therefore, the handheld unit is precluded from classification under subheading 8528.52.0000, HTSUS. In your original submission, you also suggest that the imager cable is correctly classified under subheading 8541.90.0000, HTSUS, which is provided for "Semiconductor" devices (for example, diodes, transistors, semiconductor-based transducers); photosensitive semiconductor devices, including photovoltaic cells whether or not assembled in modules or made up into panels; light-emitting diodes (LED), whether or not assembled with other light-emitting diodes (LED); mounted piezo-electric crystals; parts thereof: Parts." However, heading 8541 is reserved for discrete semiconductor devices that do not include combinations of goods from two or more distinct groups enumerated in heading 8541, or combinations of goods of heading 8541 and other headings, when the combination of goods does not contribute to a single function covered by a single group enumerated in heading 8541. Consequently, subheading 8541.90.0000, HTSUS, is not applicable, as the subject item is not considered a part of discrete semiconductor devices of heading 8541.

The applicable subheading for the handheld unit and the imager cable when imported separately will be 8529.90.8700, HTSUS, which provides for other “Parts suitable for use solely or principally with the apparatus of headings 8524 to 8528: Other of articles of headings 8525 and 8527: Other.” The rate of duty will be free.

The 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/.

This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the classification stated above, the merchandise covered by this ruling may also need to be reported with either the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions covering exceptions to such tariffs.

For further information to assist with the importation process, please refer to the frequently updated Cargo Systems Messaging Service (CSMS) messages at https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and the Trade Remedies page at https://www.cbp.gov/trade/programs-administration/trade-remedies.

According to the information provided, the main printed circuit board assemblies (PCBAs) for both the handheld unit and the imager cable are manufactured in Taiwan through surface mount technology (SMT) processes, including solder paste printing, SMD placement, reflow soldering, AOI, and functional testing. The PCBA in the handheld unit functions as microprocessor control, image processing, storage, display driving, and LED control. The PCBA in the imager cable contains the CMOS sensor interface, LED driver, and signal transmission. The image sensor is also fabricated in Taiwan.

In China, the handheld unit is assembled, which includes injection molding of housings, LCD/button pad assembly, and mechanical fastening. The assembly process for the imager cable also takes place in China. This process includes wire processing and threading, soldering, lens focusing, adhesive potting, and housing integration.

When determining the country of origin for purposes of applying current trade remedies under Section 301 and additional duties, the substantial transformation analysis is applicable. See, e.g., Headquarters Ruling Letter (“HQ”) H301619, dated November 6, 2018. The test for determining whether a substantial transformation will occur is whether an article emerges from a process with a new name, character, or use different from that possessed by the article prior to processing. See Texas Instruments Inc. v. United States, 681 F.2d 778 (C.C.P.A. 1982). This determination is based on the totality of the evidence. See National Hand Tool Corp. v. United States, 16 C.I.T. 308 (1992), aff’d, 989 F.2d 1201 (Fed. Cir. 1993). Based on the information provided, it is the opinion of this office that the PCBAs are the dominant components of these products. Additionally, the assembly process performed in China would not substantially transform the PCBAs of Taiwanese origin into a new and different article of commerce with a name, character, and use distinct from that of the exported good. Accordingly, the country of origin of the handheld unit and the imager cable when imported separately and when imported together is Taiwan.

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 Lisa Cariello at [email protected].
Sincerely,

(for)
James P. Forkan
Director
National Commodity Specialist Division