CLA-2 CO:R:C:G 083616 JLJ
Mr. William M. B. Ajemian
Blaser & Mericle, Inc.
1946 N. 13th Street, Suite 360
Toledo, Ohio 43624
RE: Photographic Illuminators
Dear Mr. Ajemian:
This is in reference to your request for a tariff
classification ruling under the Harmonized Tariff Schedule of
the United States Annotated (HTSUSA) for a photographic
illuminator made in the United Kingdom. You submitted a sample
and descriptive literature along with your request.
FACTS:
The sample is made of a woven fabric of man-made fibers
over a spring steel rim. It folds up to fit in its case. When
unfolded, the illuminator is shaped like a square with round
corners. It is available in several colors or color
combinations (e.g., silver/white, gold/white, silver/black and
translucent) and several sizes (20, 30 and 42 inches in
diameter).
The illuminators can be used in both indoor and outdoor
photography. The size and color of illuminator used depends
upon the type of photography involved and upon the effects
desired. The 20 inch size is recommended for close-ups or
table-top work. The 42 inch size is used for cinematography.
The illuminator can be used with flash apparatus, with
photographic studio lamps, with other lighting apparatus and
with regular outdoor lighting.
-2-
Some of the uses of the illuminator are as follows (the
fabric color for each is shown in parentheses): (1) as a
reflector for soft portrait illumination (white), (2) to absorb
unwanted light by subtraction (black), (3) as a reflector to
give warm tones (gold), (4) as a reflector to give sharp tones
and the optimum reflectivity for portraiture (silver), and (5)
for use as a diffuser when placed between the light source and
the subject being photographed (translucent).
ISSUE:
What is the classification of the photographic
illuminator?
LAW AND ANALYSIS:
In Customs Headquarters Ruling Letter (HRL) 085198 of
November 17, 1989, two similar photographic reflectors for use
in photography were assumed, absent evidence to the contrary,
to be principally used as accessories for photographic
flashlight apparatus. The reflectors were classified as
other accessories for photographic flashlight apparatus in
subheading 9006.99.0000, HTSUSA.
Absent evidence to the contrary, we follow HRL 085198 in
assuming that the instant merchandise is principally used as
an accessory for photographic flashlight apparatus and must
therefore be classified in subheading 9006.99.0000, HTSUSA,
dutiable at the rate of 3.9 percent ad valorem.
HOLDING:
The photographic illuminator is classified under the
provision for other accessories for photographic flashlight
apparatus in subheading 9006.99.0000, HTSUSA.
Sincerely,
John Durant, Director
Commercial Rulings Division
hensley library
j.johnson
083616JLJ