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NY J82325

March 31, 2003



TARIFF NO.: 8525.30.9005, 8528.21.5501

Ms. Natalie Baron
International Marketing Department
Times Corporation Ltd
Takatsukasa 1-6-11, Takarazuka- City
Hyogo, 665-0051, Japan

RE: The classification of a CCD camera with stand from Japan.

Dear Ms. Baron:

In your letter dated March 18, 2003 you requested a tariff classification ruling. The literature you have submitted states that the Assist Vision 100 (AV-100) is an assembled device composed of a stand with a built CCD color camera. The camera transmits live images in real time at a rate of fewer than 60 frames per second. It magnifies the image from 2x to 50x using a zoom lens and transmits the magnified image to a TV monitor that will be supplied with the system after importation. An X/Y movable table will be attached to the bottom of the stand to facilitate the smooth movement of reading material. The purpose of the device is to provide visually impaired people with magnification of reading materials

The literature you have submitted states that the Assist Vision 200 (AV-200) is a device composed of a pencil type CCD color camera, an adapter and a 6.4 monitor. The camera transmits live images in real time. It magnifies the image using a zoom lens and transmits the magnified image to the monitor. The camera and monitor are of equal importance to the system. Thus the last item to appear in the tariff gives the system its classification (GRI 3c).

The applicable subheading for the Assist Vision 100 will be, 8525.30.9005 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; television cameras; still image video cameras or other video camera recorders; digital cameras: Television cameras: Other Color. The general duty rate will be 2.1 percent ad valorem.

. The applicable subheading for the Assist Vision 200 (CCD camera with monitor) will be, 8528.21.5501 (HTS), which. Provides for reception apparatus for television, whether or not incorporating radiobroadcast receivers or sound or video recording or reproducing apparatus; video monitors and video projectors, video monitors, color, with a flat panel screen, incorporating video recording or reproducing apparatus, with a video display diagonal not exceeding 34.29 cm. The general rate of duty will be free.

Your AV-200 includes a monitor. Since it is designed to greatly magnify only flat surfaces such as newsprint and photographs, it would not be of significant use to watchmakers, surgeons, or most others who are sighted, but need extremely high magnification to perform tasks on or to inspect small objects. Those who have vision correctable by spectacles, etc, would find little need for such an elaborate device: those whose vision is not correctable are most likely legally blind. Your item is similar to the one described in New York Ruling Letter G82034, dated 9-29-00. On that basis, we agree that a secondary classification will apply for the AV-200 in HTS 9817.0094, as specially designed or adapted for the exclusive use or benefit of the permanently or chronically blind, free of duty and user fees (if any) if all applicable entry requirements are met including the filing with the Customs port of entry of the U.S. Department of Commerce form ITA-362P.

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 646-733-3014.

If you have any questions regarding the classification in 9817.00.94 of this item, contact National Import Specialist Jim Sheridan at 646-733-3012.


Robert B. Swierupski

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