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NY H81870

May 30, 2001

CLA-2-85:RR:NC:1:108 H81870


TARIFF NO.: 8525.40.4000

Ms. Lydia E. Lorenzo
Ricoh Corporation
Five Dedrick Place
West Caldwell, NJ 07006

RE: The tariff classification of a digital image-capturing device.

Dear Ms. Lorenzo:

In your letter dated May 15, 2001 you requested a tariff classification ruling.

The item in question is denoted as a digital image capturing device, specifically model number RDC- i 700. The item is actually a digital still image camera, which also provides Internet access and data management capability as a PDA (personal digital assistant), primarily for the captured digital images.

This device allows the user to take and store digital still images. These images can be edited with text and transmitted over the Internet to either someone’s E-mail, a web-site or directly to a fax machine. It has a 3.5 inch fold-up LCD screen which can be used to view the images and also serves as a touch screen keypad for the manipulation of data for storage in your own files or folders.

Section XVI Note 3 provides “ Unless the context otherwise requires, composite machines consisting of two or more machines fitted together to form a whole and other machines adapted for the purpose or performing two or more complementary or alternative functions are to be classified as if consisting only of that component or as being that machine which performs the principal function”.

It is the opinion of this office, after review of the descriptive literature, that the principal function of this device is that of the digital still image camera. It is to be marketed and sold as an image-capturing device and the additional IT functions are based upon the use of any such images.

The applicable subheading for the RDC – i 700 digital image capturing device will be 8525.40.4000, 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 apparatus; television cameras; still image video cameras or other video camera recorders: Still image video cameras and other camera recorders: Digital still image video cameras. The rate of duty will be free.

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 Michael Contino at 212-637-7039.


Robert B. Swierupski

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