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NY K86416




June 18, 2004

CLA-2-73:RR:NC:N1:113 K86416

CATEGORY: CLASSIFICATION

TARIFF NO.: 7326.90.8587; 8525.30.9005; 8526.91.0040; 8471.50.0085; 8471.49.1500; 8471.49.1095; 8471.60.1095; 8537.10.9070

Mr. Brian Kavanaugh
Deringer Logistics Consulting Group
1 Lincoln Blvd., Suite 225
Rouses Point, NY 12979

RE: The tariff classification of automobile camera equipment from Canada.

Dear Mr. Kavanaugh:

In your letter dated May 19, 2004, you requested a ruling on behalf of Autovu Technologies on tariff classification.

The merchandise is equipment used to record information on automobiles. The Mounting System consists of camera and lights mounted on a pole that is located at the entry and exit lanes of a parking facility. You request the classification of the pole.

The applicable subheading for this product will be 7326.90.8587, Harmonized Tariff Schedule of the United States (HTS), which provides for other articles of iron or steel, other. The general rate of duty will be 2.9 percent ad valorem.

The AutoFind Mobile License Plate Reading System consists of cameras and lights mounted on the outside of a vehicle. The cameras employ standard CCD technology. The camera output is sent via wire to a computer located inside the vehicle. The computer is a standard PC running Windows XP. The system also contains a GPS mapping unit. A touch-screen control for the system is installed in the passenger compartment.

In our opinion, the system is not classifiable as an entirety. Because of the complexity of the system and its options, we can only supply classifications for the major components. We would recommend that you request rulings on any minor components separately, if necessary.

The applicable subheading for the cameras will be 8525.30.9005, Harmonized Tariff Schedule of the United States (HTS), which provides for Transmission apparatus for radiotelephony, radiotelegraphy, radiobroadcasting or television, whether or not incorporating reception apparatus or sound recording or reproducing; television cameras; still image video cameras or other video camera recorders; digital cameras: Television cameras: Other Color. The general rate of duty will be 2.1 percent ad valorem.

The applicable subheading for GPS unit will be 8526.91.0040, Harmonized Tariff Schedule of the United States (HTS), which provides for Radar apparatus, radio navigational aid apparatus and radio remote control apparatus: Other: Radio navigational aid apparatus ... Other. The general rate of duty will be free.

When imported as a system which includes the PC and the touch screen, the applicable subheading for the PC with the cable bundle will be 8471.49.1095, Harmonized Tariff Schedule of the United States (HTS), which provides for digital processing units entered with the rest of a system, whether or not containing in the same housing one or two of the following units: storage units, input units, or output units. The general rate of duty will be free. The applicable subheading for the touch screen will be 8471.49.1500, Harmonized Tariff Schedule of the United States (HTS), which provides for Automatic data processing machines and units thereofOther digital automatic data processing machines: Other, entered in the form of systems: Input or output units, entered with the rest of a system, whether or not containing storage units in the same housing, combined input/output units. The general rate of duty will be free.

When imported separately, the applicable subheading for the PC will be 8471.50.0085, Harmonized Tariff Schedule of the United States (HTS), which provides for Automatic data processing machines and units thereof Digital processing units other than those of subheading 8471.41 or 8471.49, whether or not containing in the same housing one or two of the following types of unit: storage units, input units, output units: Other. The general rate of duty will be free. The applicable subheading for the touch screen will be 8471.60.1095, Harmonized Tariff Schedule of the United States (HTS), which provides for Automatic data processing machines and units thereof Input or output units, whether or not containing storage units in the same housing: Combined input/output units: Other. The general rate of duty will be free. Your inquiry does not provide enough information for us to give a classification ruling on separately imported cable bundles. Your request for a classification ruling should include a sample or a picture of the bundles.

The Telecom custom-built controller provides switching power to the illuminators and cameras. It also provides inertial navigation information.

The applicable subheading for this product will be 8537.10.9070, Harmonized Tariff Schedule of the United States (HTS), which provides for other boards, , for electric control or the distribution of electricity, : For a voltage not exceeding 1,000 V. The general rate of duty will be 2.7 percent ad valorem.

Your inquiry does not provide enough information for us to give a classification ruling on the base station computer. Your request for a classification ruling should include what type of computer it is, what processor and operating system are used. Is there a monitor or display, keyboard or other input or output devices? If so, what type? When this information is available, you may wish to consider resubmission of your request. 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.

This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R.).

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 James Smyth at 646-733-3018.

Sincerely,

Robert B. Swierupski
Director,

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