CLA-2-85:OT:RR:NC:N2:208
Ms. Elizabeth K. Lowe
Venable LLP
600 Massachusetts Avenue, NW
Washington, District of Columbia 20001
RE: The tariff classification of cameras from Thailand
Dear Ms. Lowe:
In your letter dated March 29, 2022, on behalf of Vivint Inc., you requested a tariff classification ruling.
The merchandise under consideration is the outdoor camera systems, the Vivint’s Outdoor Camera Pro, Model No. VS-ODC300-WHT and the Doorbell Camera Pro, Model No. VS-DBC300-WHT, both of which are used for home monitoring and surveillance.
The Outdoor Camera Pro is designed to be installed outside the house, to surveil specific outdoor areas. The Outdoor Camera Pro has a 4k Ultra HD sensor and a 140° field of view. Moreover, the Outdoor Camera Pro uses motion detection together with a propriety image recognition algorithm to capture and record video and still images onto its 1GB of SDRAM and 8 GB eMMC internal memory card. The recorded video clips are stored in the camera as a video file (MP4) format and the standalone still images are stored in the camera as a still image (JPEG) format.
The Doorbell Camera Pro, which has a 1080p HD with a High Dynamic Range image sensor, and a 180° x 180° field of view, is designed to be installed at a user’s door. It uses motion detection together with a propriety image recognition algorithm to capture and record video and still images. The “real-time” video is automatically transmitted to a smartphone application. Once a triggering event occurs, the subject camera is programmed to capture a still image and video, and record both onto its 1GB SDRAM and 8 GB eMMC internal memory card. According to the information provided, the video clips recorded are stored internally in a video file (MP4) format and the standalone still images are recorded on the camera's internal memory in a still image (JPEG) format. Moreover, the Doorbell Camera Pro has a subsidiary feature of a two-way talk function that operates over the Wi-Fi network, which allows users to use their smartphone application as an intercom to speak to the visitor on the doorstep and hear the response.
The applicable subheading for the subject cameras that can capture and record still and moving images will be 8525.89.4000, 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: Other: Digital still image video cameras.” 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 the 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 Lisa Cariello at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division