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HQ 083616

February 12, 1990

CLA-2 CO:R:C:G 083616 JLJ


TARIFF NO.: 9006.99.00

Mr. William M. B. Ajemian
Blaser & Mericle, Inc.
1946 N. 13th Street, Suite 360
Toledo, Ohio 43624

RE: Photographic Illuminators

Dear Mr. Ajemian:

This is in reference to your request for a tariff classification ruling under the Harmonized Tariff Schedule of the United States Annotated (HTSUSA) for a photographic illuminator made in the United Kingdom. You submitted a sample and descriptive literature along with your request.


The sample is made of a woven fabric of man-made fibers over a spring steel rim. It folds up to fit in its case. When unfolded, the illuminator is shaped like a square with round corners. It is available in several colors or color combinations (e.g., silver/white, gold/white, silver/black and translucent) and several sizes (20, 30 and 42 inches in diameter).

The illuminators can be used in both indoor and outdoor photography. The size and color of illuminator used depends upon the type of photography involved and upon the effects desired. The 20 inch size is recommended for close-ups or table-top work. The 42 inch size is used for cinematography.

The illuminator can be used with flash apparatus, with photographic studio lamps, with other lighting apparatus and with regular outdoor lighting.

Some of the uses of the illuminator are as follows (the fabric color for each is shown in parentheses): (1) as a reflector for soft portrait illumination (white), (2) to absorb unwanted light by subtraction (black), (3) as a reflector to give warm tones (gold), (4) as a reflector to give sharp tones and the optimum reflectivity for portraiture (silver), and (5) for use as a diffuser when placed between the light source and the subject being photographed (translucent).


What is the classification of the photographic illuminator?


In Customs Headquarters Ruling Letter (HRL) 085198 of November 17, 1989, two similar photographic reflectors for use in photography were assumed, absent evidence to the contrary, to be principally used as accessories for photographic flashlight apparatus. The reflectors were classified as other accessories for photographic flashlight apparatus in subheading 9006.99.0000, HTSUSA.

Absent evidence to the contrary, we follow HRL 085198 in assuming that the instant merchandise is principally used as an accessory for photographic flashlight apparatus and must therefore be classified in subheading 9006.99.0000, HTSUSA, dutiable at the rate of 3.9 percent ad valorem.


The photographic illuminator is classified under the provision for other accessories for photographic flashlight apparatus in subheading 9006.99.0000, HTSUSA.


John Durant, Director

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