CLA-2-90:OT:RR:NC:N1:405
Marc Giannini
AMG Customs Solutionsm, Inc.
150 South 8th Street, # 225
Lewiston, NY 14092
RE: The tariff classification of the NavVis M3-6 Mapping Trolley from Germany
Dear Mr. Giannini:
In your letter dated September 8, 2016, on behalf of NavVis GMBH, you requested a tariff classification ruling.
The product at issue, identified as the NavVis M3-6 Mapping Trolley, is a device used in the creation of detailed, three-dimensional digital maps of indoor spaces. The wheeled trolley is equipped with three laser scanners, six 16-megapixel digital cameras, an inertial measurement unit (IMU), and additional sensors to record WiFi signals, Bluetooth, and magnetic fields. The trolley, which is not self-propelled, measures approximately 78" (H) by 31" (W) by 37" (D) and weighs roughly 90 pounds. When not in use, the trolley can be disassembled and stored in a transport case.
To use the Mapping Trolley, a user will slowly wheel the device through the facility to be mapped. The laser scanners and IMU collect data about the horizontal and vertical dimensions of the space, while the cameras capture images. The data and images are processed by the trolley’s onboard software to create a detailed three-dimensional map of the facility’s interior, combined with panoramic photos of the indoor environment. When the mapping process is completed, the finished digital maps can be viewed via a web browser-based computer application, or on a smartphone. The Mapping Trolley is intended to create continuous digital maps in a variety of interior environments, ranging from airports and train stations to retail establishments and museums.
The Mapping Trolley utilizes laser scanners, cameras, an IMU, and other sensors to create digital maps of interior spaces. Heading 9015 of the Harmonized Tariff Schedule of the United States (HTSUS) includes surveying instruments and appliances. The Harmonized System Explanatory Notes (ENs) to heading 9015 indicate that the heading includes instruments “intended for use in the field, for example, in cartography (land and hydrographic maps).” While the ENs do not provide a definition of the term “cartography,” the Merriam-Webster Dictionary online edition defines it as “the science or art of making maps.” As the primary function of the Mapping Trolley is the creation of indoor digital maps, the product would be appropriately classified in heading 9015.
The applicable subheading for the NavVis M3-6 Mapping Trolley will be 9015.80.2000, HTSUS, which provides for Surveying (including photogrammetrical surveying), hydrographic, oceanographic, hydrological, meterological or geophysical instruments and appliances, excluding compasses; rangefinders; parts and accessories thereof: Other instruments and appliances: Optical instruments and appliances. 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 Evan Conceicao at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division