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NY N011212

June 4, 2007



TARIFF NO.: 8525.80.3010

Ms. Moncy Nabors
JCPenny Purchasing Corporation
6501 Legacy Drive
Plano, TX 75024-3698

RE: The tariff classification of a child’s video camera set from China.

Dear Ms. Nabors:

In your letter dated May 7, 2007, you requested a tariff classification ruling. Sample is being returned as requested.

The submitted sample is a battery-operated plastic child’s video camera set, which is referred to as the “MP3 Video & Sound System.” This apparatus consists of a video camera and a sound speaker that operates as a composite machine with the capability of capturing and transmitting live-color images and audio directly to the TV or VCR, but without any recording or storing capability; furthermore, it has a built-in cable, within the MP3 player or iPod compartment (not including an MP3 player or iPod), for enabling the reproduction of music through the speaker. This composite machine also incorporates the following: a lens, a view finder, a power switch, a video switch, volume controls, a headphone socket, an AV-out socket, a microphone socket and holder, a battery compartment, a LED power indicator, a video indicator, and a tripod socket.

At the time of importation, this apparatus will be retail-packed with an AV cable for the transmission of images and audio, a microphone for singing, and an instruction guide of operating procedures. This combination will be considered a set for tariff classification purposes with the essential character being imparted by the composite machine: the video camera and speaker. Moreover, the principal function of the composite machine is performed by the video camera.

The applicable subheading for this merchandise will be 8525.80.3010, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Transmission apparatus for radio-broadcasting or television, whether or not incorporating reception apparatus or sound recording or reproducing apparatus Television cameras, digital cameras and video camera recorders: Television cameras: Other: Color. The rate of duty will be 2.1 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 Lisa Cariello at 646-733-3014.


Robert B. Swierupski

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