Panasonic WG-R2 Two-Way Still-Picture Transceiver

HQ 082559 September 25, 1989 CLA-2 CO:R:C:G 082559 JMH CATEGORY: Classification TARIFF NO.: 8517.81.20 Mr. William R. Palle Panasonic Industrial Company One Panasonic Way Secaucus, New Jersey 07094 RE: Panasonic WG-R2 Two-Way Still-Picture Transceiver Dear Mr. Palle: Your request of May 10, 1988, for a ruling on the classification of the Panasonic WG-R2 Two-Way Still-Picture Transceiver has been referred to this office for a reply. FACTS: The WG-R2 Two-Way Still-Picture Transceiver (WG-R2) connects to any modular telephone. It consists of a still-picture video camera incorporated into a black and white television monitor. The unit allows the user to transmit a still-picture image -- either of the sender or of an object in the sender's vicinity -- to a receiving party. The receiving party must have a compatible unit. The WG-R2 is not imported with a modular telephone, but does require connection to the same in order to function. ISSUE: What is the proper classification of the WG-R2 under the Harmonized Tariff Schedule of the United States? LAW AND ANALYSIS: Classification of merchandise under the HTSUSA is governed by the General Rules of Interpretation (GRI's). GRI 1 states in part that "for legal purposes, classification shall be determined according to the terms of the headings and any relative section or chapter notes..." It is the opinion of this office that heading 8517, HTSUSA, is the appropriate classification. Heading 8517 describes -2- "Electrical apparatus of line telephony...including such apparatus for carrier-current line systems; part thereof..." Since WG-R2 is an electrical appliance to be used with a modular telephone system, it fits within this heading. HOLDING: The proper classification for the Panasonic WG-R2 Two-Way Still-Picture Transceiver is under heading 8517.81.20, HTSUSA. The rate of duty is 8.5 percent ad valorem. Sincerely, John Durant, Director Commercial Rulings Division