The tariff classification of a surveillance security system from China

N183597 October 4, 2011 CLA-2-85:OT:RR:NC:N1:108 CATEGORY: Classification TARIFF NO.: 8525.80.30 Ms. Denise Young-Sang Office Depot 6600 North Military Trail Boca Raton, FL 33496 RE: The tariff classification of a surveillance security system from China Dear Ms. Young-Sang: In your letter dated August 22, 2011, you requested a tariff classification ruling. Sample is being retuned as requested. The subject merchandise is a surveillance security system, which is known as the Night Owl Video Security Kit (model K-42500). This system comprises the following: two television-type cameras with stands and mounting hardware, two 60-foot camera cables, a camera power adapter, a 4-channel H.264 DVR with 500GB hard drive, a DVR power adapter, a video output cable, an Ethernet cable, a two-way camera splitter, a remote control, a USB mouse, a driver CD, a quick setup guide, a user’s manual and an installation card. The cameras within this system are motion-activated and capture live images in real time, with the images being transmitted to the DVR for recording as well as to compatible devices with display screens, such as a select 3G smartphone, for remote viewing. This system, which is imported in a retail-packed condition, is considered a set for tariff classification purposes, with no one component imparting the essential character of the set. In this regard, the functions of the cameras and DVR are found to be equally essential to the operation of the system. Therefore, classification will be according to General Rule of Interpretation 3(c) which states, in relevant part, that merchandise shall be classified in the heading (in this instance, heading 8525, HTSUS) which occurs last in numerical order among those equally meriting consideration. The applicable subheading for this merchandise will be 8525.80.30, 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: Other. The rate of duty will be 2.1 percent ad valorem. 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 World Wide Web at http://www.usitc.gov/tata/hts/. 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 (646) 733-3014. Sincerely, Robert B. Swierupski Director National Commodity Specialist Division