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NY N027745





May 16, 2008

CLA-2-85:OT:RR:E:NC:N1:108

CATEGORY: CLASSIFICATION

TARIFF NO.: 8525.80.4000

Mr. Troy Crago
Atico International USA, Inc.
501 South Andrews Avenue
Fort Lauderdale, FL 33301

RE: The tariff classification of a digital camera and binocular combination from China.

Dear Mr. Crago:

In your letter dated May 6, 2008, you requested a tariff classification ruling.

The merchandise in question is a binocular with a built-in digital camera, which is denoted as product number A059DA00057. The camera has a 300K pixel CMOS sensor, an 8MB SDRAM internal memory, and a 3-digit monochrome LCD display, as well as an image resolution of 640 x 240 pixels (VGA mode) and 320 x 240 pixels (QVGA mode). In addition, the camera can store 90 images in VGA mode and 330 images in QVGA mode. When imported as a set with its accessories, it has been determined that the digital camera and binocular combination imparts the essential character of the set.

It should be noted that this office considers this camera and binocular combination to be a composite machine. This is based upon its ability to function as a still image camera, a limited video camera, and a binocular. This office believes that the principle function of this composite machine is performed by the still image video camera.

The applicable subheading for the digital camera and binocular combination will be 8525.80.4000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Transmission apparatus for radiobroadcasting or television, whether or not incorporating reception apparatus or sound recording or reproducing apparatus; television cameras, digital cameras and video camera recorders: Television cameras, digital cameras and video camera recorders: 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 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 Lisa Cariello at 646-733-3014.

Sincerely,

Robert B. Swierupski
Director,

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