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NY N021176

January 17, 2008



TARIFF NO.: 8504.40.9580

Mr. Kit Johnson
Mercedes-Benz U.S. International, Inc.
One Mercedes Drive
Vance, AL 35490

RE: The tariff classification of voltage supply module/”camera modulator” from Austria

Dear Mr. Johnson:

In your letter dated December 21, 2008 you requested a tariff classification ruling.

The merchandise subject to this ruling is a voltage supply module/”camera modulator”. The voltage supply module/”camera modulator” is assembled into the entire rear view camera system of Mercedes-Benz automobiles.

The voltage supply module/”camera modulator” consists of a populated printed circuit assembly. The printed circuit assembly contains various resistors, capacitors, and inductors, which are encased in a plastic housing. There are connections on the unit to plug in the camera’s cable and the cable to the car’s electrical system.

The voltage supply module/”camera modulator” is a direct current to direct current (DC/DC) converter. It supplies voltage from the vehicle’s electrical system to the separate rear view camera unit and forwards and amplifies the composite video baseband signal (CVBS) signal sent from the camera to the head unit/monitor. It does not modulate the CVBS signal.

The entire camera system works in the following way. When the driver engages the reverse gear, it forces a signal to be sent to switch on the exterior back-up lamps (tail lights) of the vehicle. One of the two back-up lamps sends an electrical pulse to the voltage supply module. The voltage supply module activates the camera by supplying it with voltage. As the camera captures CVBS analog images in real time, these CVBS signals are sent back to the voltage supply module, which in turn transmits the CVBS signals to the head unit for video display to the driver on the monitor of the head unit. Although the entire system contains a camera and a monitor, they are not part of the voltage supply module/”camera modulator” unit. They are a part of the entire system, as the voltage supply module/”camera modulator is.

As such, the voltage supply module/”camera modulator” is a DC/DC converter that converts direct current power from the vehicle’s electrical system for further use with the rear view camera unit. Subsequently, it forwards and amplifies the CVBS signal from the camera to the head unit/monitor.

The applicable subheading for the voltage supply module/”camera modulator” will be 8504.40.9580, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Static converters: Other: Other.” The rate of duty will be 1.5 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 Linda M. Hackett at 646-733-3015.


Robert B. Swierupski

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