CLA-2-85:OT:RR:NC:1:108
Mr. Robert D. Lilley
Doosan Infracore Portable Power
1293 Glenway Drive
Elkin, NC 28625
RE: The tariff classification of a mobile surveillance system.
Dear Mr. Lilley:
In your letter dated October 2, 2009, you requested a tariff classification ruling on a mobile surveillance system, which you plan to export.
The subject merchandise, which is known as the Blackhawk MVS-6 Mobile Surveillance System, is an optical surveillance system, for outdoor use, that consists of a towable wheeled pole-shaped structure onto which is mounted, at the top of its movable mast, a versatile, controllable digital camera with day/night image capability; a lighting system; and a separate electronics pod, which is stated to contain the Wi-Fi radio, the video encoder/DVR, the camera motor controller, the serial-to-Ethernet converter, the Ethernet switch, and associated wiring and hardware. There is also an engine, with an alternator for operating and charging purposes, as well as a generator, attached to the engine, for supplying direct power to the system when the engine is running; and a hybrid battery-charging system, all of which are attached to the lower portion of the structure.
It is stated that the camera, which does not have any built-in recording capability, operates in the manner of a surveillance camera by capturing live images in real time, which can be displayed at a remote site; these captured images can be recorded through the DVR, which can provide up to one week of continuous recording while being viewed. It is also stated that the video output from the digital camera goes to the encoder, where the DVR is contained, which translates the video from an analog CCTV-type signal to a digital Internet Protocol (IP) signal; then the IP video connects to the Wi-Fi radio unit for transmission to a remote location for viewing.
It is noted that the hybrid power system utilizes an optimal mix of solar and diesel technology to ensure up to six months of uninterrupted remote operation, and that the lighting system consists of two 1,000-watt tungsten bulbs, which are capable of manual or automatic operation.
Moreover, the wireless communication system of this merchandise allows operators to remotely control multiple units simultaneously and in real time, including the engine, fuel, digital camera, DVR, and lighting.
This merchandise is considered to be a composite good with no one component imparting the essential character and, therefore, classification will be according to General Rule of Interpretation 3(c) in the heading that appears last in the tariff among the competing provisions, thereby allowing classification within the subheading for the video surveillance camera.
The applicable subheading for the Blackhawk MVS-6 Mobile Surveillance System will be 8525.80.30, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Transmission apparatus for radio-broadcasting or television, whether or not incorporating reception apparatus or sound recording or reproducing apparatus…Television cameras, digital cameras and video camera recorders: Television cameras: Other.
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,
Robert B. Swierupski
Director
National Commodity Specialist Division