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Sept. 30 CBP Bulletin Proposes to Revoke Rulings on Digital Camera Inspection Systems

In the Sept. 30 Customs Bulletin (Vol. 54, No. 38), CBP published notices that propose to revoke rulings and similar treatment for digital camera inspection systems.

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Comments on Proposals Due Oct. 30

CBP said consideration will be given to any written comments received by Oct. 30 before taking this action. In addition, any party that has received a ruling or decision on the merchandise that is subject to the proposed revocations or modifications, or any party involved with a substantially identical transaction, should advise CBP by the date that written comments on the proposed ruling are due. (An importer's failure to advise CBP of such rulings, decisions or substantially identical transactions may raise issues of reasonable care on the part of the importer or its agents for importations subsequent to the effective date of the final decision in this notice.)

Proposals

CBP is proposing to revoke or modify the rulings below, and any rulings on these products that may exist but have not been specifically identified. CBP is also proposing to revoke any treatment it has previously accorded to substantially identical transactions.

Digital Camera Inspection Systems

Item: A portable video system for inspecting difficult-to-access spaces that consists of a camera, monitor, cables, power supply, guidance ball, and guidance sleeve.
Current: Heading 8528, Free, “Monitors and projectors, not incorporating television reception apparatus; reception apparatus for television, whether or not incorporating radio-broadcast receivers or sound or video recording or reproducing apparatus.”
Proposed: 8525.80.30, Free, “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, digital cameras and video camera recorders: Television cameras: Other.”
Reason: As the monitors merely display the captured images, and images recorded on a storage card may be displayed on devices other than the monitor, the monitors do not perform the principal function of the subject inspection systems and their role is subsidiary to that of the cameras, CBP said. “In this regard, we find that the display component of the instant inspection system functions the same as the optical viewfinder or LCD commonly found on digital video cameras of heading 8525.”
Proposed for revocation: NY N107616, dated June 23, 2010, and NY N225535, dated July 26, 2012
Proposed new ruling: HQ H270703