CLA-2-90:OT:RR:E:NC:1:114
Mr. David Freeman
The Flash Emporium
408 Summit Avenue
Mount Vernon, NY 10552
RE: The tariff classification of photographic studio equipment from China
Dear Mr. Freeman:
In your letter dated December 30, 2008, you requested a tariff classification ruling.
You are requesting rulings for four items of photographic studio equipments.
The first item is an electronic flash unit. It is a non-automatic, AC-powered studio monobloc, i.e. self-contained flash unit measuring approximately 10 inches long by 6 inches in diameter. It has an electronic flash tube and accessory mounting apparatus at one end, and electronic controls and power cord socket at the other end. The lights have an integral, adjustable tilting 5/8 inch receptacle on their bottom surface which allows them to be mounted on standard studio light stands and pointed as desired. The stored power of the lights to be imported are 300WS, 500WS, and 800WS. Control of the lights is fully manual as they are without automation of any kind.
The second item is an electronic photographic flash unit which consists of two parts: a power pack/control unit containing a battery as the power source, and a separate cable-connected flash head containing the actual flash tube and an accessory mounting apparatus. The flash unit will be imported and packaged together in soft-sided carrying case. The case is fitted for the contents. The flash unit consists of one power pack of 600WS stored energy. It measures approximately 5 inches wide by 10 inches long by 10 inches tall. It has one flash head with attached 9–foot connecting cable, one rechargeable battery for the power pack, one charging unit for the battery, one recharging adapter to allow recharging of the battery outside of the power pack, one electronic flash triggering device, and one clip-on carrying strap for the power pack.
The third item is a parabolic reflective umbrella for photographic studio use. The umbrella measures 1.7 meters (approximately 67 inches) in diameter when opened. It contains a central shaft onto which a studio-type flash unit can be mounted facing toward the interior of the umbrella canopy. The shaft can be moved toward or away from the umbrella canopy allowing control over the spread of light the umbrella will produce. The umbrella is imported with a dedicated, collapsible mounting stand with an adjustable tilting mount for the umbrella, a tripod base and three casters.
The applicable subheading for the electronic flash unit, non-automatic, AC-powered studio monobloc and the electronic photographic flash unit will be 9006.61.0060, Harmonized Tariff Schedule of the United States (HTSUS), which provides for photographic flashlight apparatus and flashbulbs: discharge lamp ("electronic") flashlight apparatus, other. The rate of duty will be free.
The applicable subheading for the parabolic reflective umbrella for photographic studio will be 9006.99.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for photographic (other than cinematographic) cameras; photographic flashlight apparatus; parts and accessories thereof: other. The rate of duty will be 3.9 percent.
The fourth item you refer to as the Sprite S-180 studio small portrait lighting kit. The kit consist of three S-180 AC powered monobloc photographic flash units of 180WS (Watt Seconds) power each, three multi-section collapsible aluminum light stands with folding tripod bases, two folding 40 inch photographic umbrellas with white interiors and black exteriors, one folding “softbox” type light modifier with a translucent front panel measuring 50 centimeters by 70 centimeters when assembled, one accessories kit containing a plastic mounting adapter for the light along with a honeycomb grid and 3 plastic color filters and one electronic flash triggering device.
You state that the Sprite S-180 kit will be imported packaged in two configurations. The first one is in a soft-sided carry bag containing the three S-180 lights, and one soft-sided carry bag containing the light stands, the umbrellas, and the softbox. The second is the complete kit packaged in a single rolling bag.
We are unable to give a classification ruling for the Sprite S-180 studio small portrait lighting. Please submit working samples of the Sprite S-180 studio small portrait lighting in their imported condition, and in the two packaging configurations as mentioned in your letter. When this information is available, you may wish to consider resubmission of your request for the Sprite S-180. We are returning any related samples, exhibits, etc. If you decide to resubmit your request, please include all of the material that we have returned to you.
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 Barbara Kiefer at (646) 733-3019.
Sincerely,
Robert B. Swierupski
Director
National Commodity Specialist Division