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HQ 088843

June 3, 1991

CLA-2 CO:R:C:M 088843 CMS


TARIFF NO.: 8525.30.00, 8479.89.60

Mr. C. Marcus Rich
Vice President, Support Systems
Optech International, Ltd.
321 No. Front Street
Wilmington, NC 28401

RE: Bioscanner; Television Camera; Robotic Arm; Zoom, Focus Controls; Video Monitor

Dear Mr. Rich,

This is in response to the request dated January 29, 1991, forwarded by Lynden Airfreight, Inc., for a classification ruling on a product imported by Optech International Ltd., described as the Bioscanner. Our ruling follows.


The merchandise is described by the importer as the "Bioscanner". The product consists of a CCD television camera mounted on a robotic arm with controls for the robotic arm movement and camera focus and zoom. A lighting control box and rotating turntable may be entered with the camera and robotic arm.

The product is used to track and record the behavior of specimens such as Axolotl (Mexican walking fish), sea anemones and shore lizards in prepared habitats. The images are displayed on a video monitor which is added to the camera and robotic arm after importation. The Bioscanner is entered disassembled.

The ruling requestor inquires about the classification of the merchandise in those cases when it would not be eligible for the free rate of duty under 9810.00.60, HTSUSA.


Is the merchandise classified as a television camera in Heading 8525, or as a robotic apparatus in Heading 8479?


The Harmonized Tariff Schedule of the United States Annotated (HTSUSA) provides that the classification of articles is governed by the General Rules of Interpretation (GRI's). GRI 1 states in pertinent part that "...classification shall be determined according to the terms of the headings and any relative section or chapter notes...".

The product is not described by the terms of any single heading. Section XVI Note 3 provides in pertinent part that composite machines consisting of two or more machines fitted together to form a whole and other machines adapted for the purpose of performing two or more complementary or alternative functions are classified as if consisting of only that component which performs the principal function.

The merchandise is a Section XVI Note 3 composite machine consisting essentially of a television camera fitted to a robotic positioning arm. The components are assembled after importation and are classified as the assembled machine pursuant to GRI 2.

The television camera is the component which actually records the behavior of the specimens and is the component which performs the principal function. The robotic arm merely positions the camera. The lighting control box and turntable are also subsidiary components.

The merchandise is classified as a television camera in 8525.30.00, HTSUSA.


The merchandise is classified as a television camera in 8525.30.00, HTSUSA. The current rate of duty is 4.2% ad valorem for products with New Zealand as their country of origin.


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