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