In ruling NY N324932 (Apr. 13, 2022), Customs and Border Protection (CBP) discussed the tariff classification of an outdoor security camera system from China. The camera system, known as the Outdoor Wire-free Security Camera, is a wireless home security camera that consists of the following items: two wire-free outdoor cameras “EufyCam 2C” (model number T8113S), the “HomeBase 2” (model number T8010X), a user manual, marketing materials, a power adapter, an Ethernet cable, wall mounts, a reset pin needle, two mounting screw packs, a USB charging cable, a HomeKit card, and an installation positioning card. All of the items are imported together and packaged for retail sale as a set.

Once imported, the two wire-free cameras are connected to the HomeBase unit via Wi-Fi – which allows the user to view live footage or recordings captured by the cameras. The cameras have a 135-degree field of view, a built-in spotlight, a 100-decibel siren, and motion detection capabilities for both pets and humans. If motion is detected, the camera will begin to capture video and transmit the “real-time” video back to the HomeBase unit and the user’s mobile phone for remote viewing or recording. The cameras have no internal recording capabilities.

CBP stated that the outdoor cameras impart the essential character of the set. As such, the cameras, which are used as electronic surveillance tools to provide security to the user’s home, are used to classify the product. CBP determined that the applicable subheading for the outdoor camera security system is 8525.89.3000, 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, digital cameras and video camera recorders: Television cameras: Other.”  The rate of duty is free.

Additionally, pursuant to U.S. Note 20 to Subchapter III, Chapter 99, HTSUS, Chinese products under subheadings 8525.89.3000, HTSUS, unless specifically excluded, are subject to an additional 25% ad valorem duty rate. As such, the chapter subheading 9903.88.03 must be reported in addition to subheading 8525.89.3000, HTSUS.