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NY N014836

August 7, 2007



TARIFF NO.: 8528.59.2500

Mr. M. Jason Cunningham
Sonnenberg & Anderson
300 South Wacker Drive
Suite 1220
Chicago, IL 60606

RE: The tariff classification of a flat panel video monitor from Japan.

Dear Mr. Cunningham:

In your letter dated July 24, 2007, on behalf of Optrex America, Inc., you requested a tariff classification ruling.

The modules under consideration are color-TFT liquid crystal display (LCD) monitors, which are denoted as part numbers T-55195GD024H-T-AND and T-55229GD0635HT-ABN. These devices are 2.4 inch or 3.5 inch diagonal video monitors that are part of an automobile’s rear-view camera system. These video displays are incorporated into an automobile’s rear-view mirror to reduce or eliminate “blind spots,” thereby increasing vehicle safety. When the vehicle is shifted into reverse, the LCD screen in question will automatically appear within the reflective surface of the mirror, showing a real-time view of the area at the rear of the vehicle. Once the vehicle is shifted into any other gear, the display disappears. These monitors are not used for rear seat entertainment.

In your original letter, you express the opinion that models T-55195GD024H-T-AND and T-55229GD0635HT-ABN are properly classified under subheading 8531.20.0020, Harmonized Tariff Schedule (HTS), which provides for Electric sound or visual “signaling” apparatus: Indicator panels: Incorporating LCD’s. However, only a small amount of information can be displayed and remain within the scope of “visual signaling apparatus.” The modules in question display an actual video image, which is more than a limited amount of information; therefore, they are precluded from being classified under heading 8531, HTS.

The applicable subheading for these LCD video monitors will be 8528.59.2500, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Monitors and projectors, not incorporating television reception apparatus; reception apparatus for television, whether or not incorporating radio-broadcast receivers or sound or video recording apparatus: Other monitors: Other: Color: With a flat panel screen: Other: With a video display diagonal not exceeding 34.29 cm. The rate of duty will be Free.

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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