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NY 853092

June 20, 1990

CLA-2-114:S:N:N1:114 853092


TARIFF NOS.: 9002.11.8000, 9802.00.5040

Mr. Richard Salvatore
Vicon Industries, Inc.
525 Broad Hollow Road
Melville, New York 11747

RE: The tariff classification of CCTV camera lenses exported for alterations, from Japan

Dear Mr. Salvatore:

In your letter dated May 23, 1990, you requested a tariff classification ruling.

Your request concerns the classification of CCTV lenses which were purchased from Chugai International of Japan and subsequently exported for conversion from a Bayonet mount to a "C" mount.
According to your letter, the lenses were purchased for use in video security cameras. Due to a change in the camera from a Bayonet mount to a "C" mount, Vicon Industries, Inc., returned the lenses to Chugai International, to have the lenses converted to a "C" mount. The steps involved in converting the lenses to a "C" mount are: removing the die-cast Bayonet end cap from the rear of the lens; mounting a plastic molded end cap to the rear of the lens; adding the "C" mount ring and retainer ring; terminating the drive cable with six pin connectors; testing all lens functions for proper operation.

Imported CCTV camera lenses are classifiable under the provision for objective lenses and parts and accessories thereof, for cameras, other, in subheading 9002.11.8000, Harmonized Tariff Schedule of the United States (HTS), dutiable at 6.6 percent ad valorem.

Articles returned to the United States after having been exported to be advanced in value or improved in condition by repairs or alterations may qualify for a partial duty exemption under subheading 9802.00.50, HTS, provided the foreign operations do not destroy the identity of the exported articles or create new or different articles. Articles entitled to this partial duty exemption are dutiable only upon the cost or value of the foreign repairs or alterations, provided the documentary requirements of Section 10.8, Customs Regulations, (19 CFR 10.8), are satisfied.

Based on the information you provided, the applicable subheading for the CCTV lenses, reimported after alteration from a Bayonet mount to a "C" mount, will be 9802.00.5040, HTS, which provides for articles returned to the United States after having been exported for repairs or alterations. Compliance with Section 10.8, Customs Regulations, is required. A copy of Section 10.8, Customs Regulations, is enclosed for your information.

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

A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction.


Jean F. Maguire
Area Director

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