The tariff classification of multifunctional cameras from Korea and China

N217582 June 4, 2012 CLA-2-85:OT:RR:NC:N1:108 CATEGORY: Classification TARIFF NO.: 8525.80.30 Mr. Mikel Hong Frontier Logistics Services 1700 N. Alameda St. Compton, CA 90222 RE: The tariff classification of multifunctional cameras from Korea and China Dear Mr. Hong: In your letter dated May 14, 2012, on behalf of Samsung Techwin America, you requested a tariff classification ruling. The merchandise at issue is multifunctional cameras, models SNP-3371 and SNP-5200H, which are used for surveillance. These PTZ dome IP cameras perform separate, distinct functions. They are television-type cameras that can transmit real-time video images to a location outside the camera for viewing or remote recording. They can also function as digital cameras that record images in the cameras themselves. Note 3 to Section XVI of the Harmonized Tariff Schedule of the United States (HTSUS) provides, in pertinent part, that unless the context otherwise requires, machines designed for the purpose of performing two or more complementary or alternative functions are to be classified as if consisting only of that component or as being that machine which performs the principal function. It is the opinion of this office that these surveillance cameras are principally used as television-type cameras. Consideration was given to classifying these dome IP cameras in subheading 8525.80.4000, HTSUS, as digital still image video cameras, as requested. However, it has been determined that these are multifunctional cameras with the principal function being performed by the capturing of real-time images, which are then transmitted to a location outside the camera for viewing and recording. Therefore, classification in subheading 8525.80.4000, HTSUS, is not appropriate. The applicable subheading for these PTZ dome IP cameras 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, Thomas J. Russo Director National Commodity Specialist Division