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NY N009962

May 3, 2007



TARIFF NO.: 8302.50.0000; 7326.90.8587; 8302.41.6080; 8301.40.6060

Mr. Joshua LaMotte
2221 Highway 36 West
Roseville, MN 55113

RE: The tariff classification of a video projector mount and accessories from China

Dear Mr. LaMotte:

In your letter dated April 18, 2007, you requested a tariff classification ruling.

The first article is called the “RPA Elite Projector Mount-RPM-(6 lbs).” It mounts a video projector to a ceiling. It is made of steel and has adjustment features, such as independent roll, pitch and yaw, integrated cable management and security. It is designed to be mounted to threaded pipe, concrete, wood studs or steel beams.

The applicable subheading for the projector mount will be 8302.50.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for base metal mountings, fittings and similar articleshat-racks, hat pegs, brackets and similar fixtures, and parts thereof. The rate of duty will be free.

The following articles are optional accessories designed to work with the projector mount. They will be imported and sold separately. Your letter indicates that you believe they should be classified in subheading 8302.50.0000, HTSUS, since they are designed specifically for use with the RPA Elite Projector Mount and cannot be used in any other applications. Subheading 8302.50.0000, HTSUS, includes parts, but does not include accessories. Consequently, the accessories when imported and sold separately are precluded from classification within this subheading.

The “Adjustable Extension Column CMA-006009-(4 lbs)” is made of steel. It is composed of an extension pipe, an adjuster tube and various threaded fasteners. Both the extension pipe and adjuster tube have a series of holes, which when aligned together, adjust the length of the column in 1 inch increments.

The “Suspended Ceiling Kit CMA-450-(10 lbs)” includes a 2 foot by 2 foot steel plate, a 10 foot safety cable, 20 foot strand wire, two outlet knockouts, four turnbuckles, wood eyebolts, concrete anchors and chrome finishing rings. The steel plate is designed to be secured by the wire and rest above a suspended ceiling. Nine threaded mounting holes provide flexibility of mounting positions.

The applicable subheading for the extension column and the suspended ceiling kit will be 7326.90.8587, HTSUS, which provides for other articles of iron or steel, other, other, other, other, other. The rate of duty will be 2.9 percent ad valorem.

The “Offset Ceiling Plate CMA-330-(6lbs)” is made of steel. It is mounted to the ceiling and allows the projector cables to be routed through the extension column and out the top of the ceiling plate for cable management. It measures 8 inches long by 8 inches wide by 4-1/2 inches high.

The applicable subheading for the ceiling plate will be 8302.41.6080, Harmonized Tariff Schedule of the United States (HTSUS), which provides for base metal mountings, fittings and similar articlesother mountings, fittings and similar articles, and parts thereof, suitable for buildings, other, of iron or steel, of aluminum or of zinc, other. The rate of duty will be 3.9 percent ad valorem.

The “Projector Lock PL-1-(10 lbs)” is made of heavy gauge steel. It is designed to prevent access to the projector mount. It is used in high-risk environments to prevent the detachment of a projector from its mount. It is made of a two-part rectangular housing that slides together to cover and secure the mount. It is locked and unlocked with the use of a key.

The applicable subheading for the projector lock will be 8301.40.6060, HTSUS, which provides for padlocks and locks (key, combination or electrically operated, of base metalother locks, other, other. The rate of duty will be 5.7 percent ad valorem.

Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.

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 Barbara Kaiser at 646-733-3024.


Robert B. Swierupski

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