CBP Ruling N238391 — The tariff classification of a network memory module from an unknown country

Tariff classification

Headings: 8521

Product description

The merchandise subject to this ruling request is the DIS-2/M NSU, which is a network memory module for audio and video streams. This merchandise, which is used in a surveillance system, is a composite machine (Note 3 to Section XVI) that receives, converts, records, and transmits real-time video and audio that are sent from a CCTV camera. It receives video in various encodings via an Ethernet network (unicast or multicast), records real-time video on its internal hard disk, and can transmit the real-time video simultaneously. The ability to record the video internally safeguards accessibility of the recording, as it is network-independent and even continues recording in the case of a malfunction or a complete network failure. In addition, the recording function reduces the demands on the network (bandwidth), since transmitting is only carried out when necessary. Therefore, it is the opinion of this office that the recording function performs the principal function of this composite machine.

CBP rationale

The applicable subheading for the DIS-2/M NSU will be 8521.90.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Video recording or reproducing apparatus, whether or not incorporating a video tuner: Other.

Full text

N238391 March 1, 2013 CLA-2-85:OT:RR:NC:N1:108 CATEGORY: Classification TARIFF NO.: 8521.90.0000 Mr. Markus Schlag Dallmeier Electronic GmbH & Co. KG Cranachweg 1 Regensburg 93051 RE: The tariff classification of a network memory module from an unknown country Dear Mr. Shlag: In your letter dated February 12, 2013, you requested a tariff classification ruling. The merchandise subject to this ruling request is the DIS-2/M NSU, which is a network memory module for audio and video streams. This merchandise, which is used in a surveillance system, is a composite machine (Note 3 to Section XVI) that receives, converts, records, and transmits real-time video and audio that are sent from a CCTV camera. It receives video in various encodings via an Ethernet network (unicast or multicast), records real-time video on its internal hard disk, and can transmit the real-time video simultaneously. The ability to record the video internally safeguards accessibility of the recording, as it is network-independent and even continues recording in the case of a malfunction or a complete network failure. In addition, the recording function reduces the demands on the network (bandwidth), since transmitting is only carried out when necessary. Therefore, it is the opinion of this office that the recording function performs the principal function of this composite machine. The applicable subheading for the DIS-2/M NSU will be 8521.90.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Video recording or reproducing apparatus, whether or not incorporating a video tuner: Other. The rate of duty will be Free. 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

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