CLA-2-85: RR:NC:1:108 E83603
Ms. Fusae Nara
Winthrop, Stimson, Putnam & Roberts
One Battery Park Plaza
New York, NY 10004-1490
RE: The tariff classification of a digital recorder.
Dear Ms. Nara:
In your letter dated June 16, 1999, on behalf of your client Sharp Electronics Corporation, you requested a tariff classification ruling.
The item in question is described as a digital recorder without a specified country of origin. It is specifically denoted as an “Internet View Cam” model VN-EZ1, MPEG-4 Digital Recorder manufactured by Sharp Electronics.
Upon further examination of the attached literature the item is in fact a digital camera which captures both still and moving images. The specific features are as follows:
- 4x Digital Zoom Lens
- Built-in speaker
- 1 hour recording capability
- 270 degree rotating camera lens
- 1.8-inch built-in LCD monitor (61,380 pixels)
- Moving picture pixel configurations of 160x120 and 320x240 for ¼ VGA
- Still image pixel configuration of 640x480
- Storage capacity of 72-576 images (normal resolution) and 36-288 images
(High-resolution) dependent upon the MB capacity of the storage memory card.
- ¼” CCD image pick-up device.
The item in question is a fully functional digital camera with storage capability. The images both still and moving can be viewed on either the incorporated LCD screen or on a standard ADP monitor. Both the still and moving images can be transmitted via a computer onto the Internet through the use of the smart media memory card. The smart media memory card is used with an ADP machine with either a floppy disk adapter or a PC card adapter.
Based upon the submitted narrative and descriptive literature it is indicated that the camera comes with software and other accessories. The characteristics of the software are not specified and it is not clear whether the accessories are included in a retail sale package. Therefore this ruling will only address the classification of the digital camera.
The applicable subheading for the Sharp Internet View Cam model VN-EZ1, MPEG-4 Digital Recorder, (digital camera), will be 8525.40.8085, Harmonized Tariff Schedule of the United States (HTS), which provides for Transmission apparatus for radiotelephony, radiotelegraphy, radiobroadcasting or television, whether or not incorporating reception apparatus or sound recording or reproducing apparatus; television cameras; still image video cameras or other video camera recorders: Still image video cameras and other video camera recorders; Other … Other. The rate of duty will be 2.1 percent ad valorem.
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 Michael Contino at 212-637-7039.
Sincerely,
Robert B. Swierupski
Director,
National Commodity
Specialist Division