The tariff classification of a cleaning kit from various countries

N295472 March 30, 2018 CLA-2-85:OT:RR:NC:N2:208 CATEGORY: Classification TARIFF NO.: 8528.52.0000 Ms. Cindi Kavanaugh Mohawk Global Trade Advisors 4455 Genesee Street Cheektowaga, NY 14225 RE: The tariff classification of a cleaning kit from various countries Dear Ms. Kavanaugh: In your letter dated March 21, 2018, on behalf of SpaceVac USA, you requested a tariff classification ruling. The merchandise under consideration is the Interior High-Level Cleaning kit, which is sold as an accessory to a vacuum. The subject Interior High-Level Cleaning kit consists of a camera, a monitor, poles, hoses, brushes, heads, connector pieces, and bags. This kit is used in janitorial and sanitation applications. The components contained within this kit allow the user to see what requires cleaning in high places via a wireless camera and a small wireless monitor. The video camera is clipped onto a head that is installed at the top end of the pole. The LCD monitor, which does not contain a tuner or a channel selector, is installed near the base of the pole at eye level. Moreover, through the monitor’s USB port, it can directly connect to and is designed for use with an automatic data processing machine of heading 8471. The camera transmits “real time” video images to the monitor so that the user can see any dust or contaminants that may need to be cleaned. The subject kit does not contain a vacuum. It is the opinion of this office that when imported packaged for retail sale, this combination meets the tariff definition of a set as per GRI 3 (b). However, neither the camera nor the monitor can function independently of one another to achieve the function of this kit. As a result, both the camera and the monitor contribute equally to the system’s function; therefore, both the camera and the monitor merit equal consideration in determining the essential character of this set. In your request, you suggest that the essential character of this kit is imparted by the camera function of heading 8525.80.3010, Harmonized Tariff Schedule of the United States (HTSUS). However, it is the view of this office that no single component can be viewed as imparting the essential character of the set. This decision is in accordance with a long line of CBP’s prior rulings that examined similar sets that incorporated video monitors and video cameras. In each of these prior rulings, we found that no single component determined the system’s essential character, and, using GRI 3(c), classified the item under Heading 8528, because it was the last numerical heading. The applicable subheading for this Interior High-Level Cleaning kit will be 8528.52.0000, HTSUS, which provides for Monitors and projectors, not incorporating television reception apparatus; reception apparatus for television, whether or not incorporating radio-broadcast receivers or sound or video recording or reproducing apparatus: Other monitors: Capable of directly connecting to and designed for use with an automatic data processing machine of heading 8471. 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 https://hts.usitc.gov/current. 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 [email protected]. Sincerely, Steven A. Mack Director National Commodity Specialist Division