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NY K81516

December 16, 2003
CLA-2-85:RR:NC:MM:109 K81516


TARIFF NO.: 8504.40.9550

Mr. David M. Murphy, Esq.
Grunfield, Desiderio, Lebowitz, Silverman & Klestadt, LLP Counselors at Law
245 Park Avenue
33 RD Floor
New York, NY 10167-3397

RE: The tariff classification of a Digital Camera Accessory Kit from China

Dear Mr. Murphy:

In your letter dated November 29, 2003, you requested a tariff classification ruling on behalf of Casio, Inc. of Dover, New Jersey.

The merchandise is described in your letter as a Digital Camera Accessory Kit Item Number CA-20AAA. The CA-20AAA Digital Camera Accessory Kit consists of an AC adapter cable, a USB cradle and a USB cable. It is sold as an accessory to digital cameras and serves to recharge the camera’s battery. It also transfers images recorded with the camera onto a personal computer (PC). It is possible to transfer the data without the use of the AC adapter for a limited amount of time. However, sudden power failure may occur resulting in the corruption of data and therefore, users are always “advised to connect the AC adapter before performing USB data communication”.

In this instance, we believe that the Digital Camera Accessory Kit Item Number CA-20AAA meets the Explanatory Notes (EN) definition of “goods put up in sets for retail sale, without further packaging or repackaging prior to sale”. First, the Digital Camera Accessory Kit consists of at least two different articles that are, prima facie, classifiable in two different headings. Secondly, the items are put together to carry out the specific activity of charging the digital camera battery. It is our opinion that the charger imparts the essential character of the Digital Camera Accessory Kit and, as such, is classifiable under heading 8504, as a static converter. The applicable subheading for the Digital Camera Accessory Kit Item Number CA-20AAA will be 8504.40.9550, Harmonized Tariff Schedule of the United States (HTS), which provides for “Electrical transformers, static converters (for example, rectifiers) and inductors; parts thereof: Static converters: Other: Other.” The rate of duty will be 1.5 percent ad valorem.

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 Linda M. Hackett at 646-733-3015.


Robert B. Swierupski

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