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NY N013597

July 16, 2007



TARIFF NO.: 8501.10.4060

Kyle R. Johanson
Vice President
J-Systems, Inc.
1 South 678 School Ave.
Lombard IL 60148

RE: The tariff classification of an unassembled electric video camera platform from the United Kingdom.

Dear Mr. Johanson:

In your letter dated June 28, 2007, you requested a tariff classification ruling.

The item concerned is the JCam IP Pan-Tilt Head. This item will be imported as a “kit” in an unassembled/incomplete state. The classification of the complete, assembled article was addressed in ruling number NY R03425. That ruling found that the JCam IP Pan-Tilt Head was classifiable in subheading 8501.10.4060, Harmonized Tariff Schedule of the United States (HTSUS). The issue at hand is the classification of the same unit when imported as a kit in an unassembled/incomplete state.

The ruling request provided a complete parts listing of the JCam IP Pan-Tilt Head “kit”. The kit will provide all of the essential components needed to assemble the unit. For example, the kit contains two 12V DC motors, gear assemblies, body castings, top plate, bottom mounting plate, motor plate, shafts, pillars, actuator springs and various other components. Once imported, the unit will be assembled in the United States. During the assembly process additional U.S. sourced parts, such as o-rings, screws, grease, potentiometers, and circuit boards will be added. Even without the addition of the U.S. sourced goods, the imported components would, on their own, assemble into a working, low tech version of the unit. Based on the information supplied the imported unit, in its unassembled/incomplete state, has the essential character of the complete/finished unit.

The applicable subheading for the JCam IP Pan-Tilt Head “kit” (unassembled electric video camera platform) will be 8501.10.4060, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "Electric motors : Motors of an output not exceeding 37.5 W: Of under 18.65 W: Other: DC: Other". The rate of duty will be 4.4%.

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 Steve Pollichino at 646-733-3008.


Robert B. Swierupski

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