Genlock; Computer Graphics; Home Video Movies; Synchronize Signals; Automatic Data Processing Machine; ADP; Video Cassette Recorder; VCR; Camcorder

HQ 089180 August 2, 1991 CLA-2 CO:R:C:M 089180 CMS CATEGORY: Classification TARIFF NO.: 8473.30.40 Mr. Marty Langtry Castelazo & Associates 5420 West 104th Street Los Angeles, CA 90045 RE: Genlock; Computer Graphics; Home Video Movies; Synchronize Signals; Automatic Data Processing Machine; ADP; Video Cassette Recorder; VCR; Camcorder Dear Mr. Langtry: This is in response to your request dated April 4, 1991, for a classification ruling on a device described as the Genlock. FACTS: The merchandise is described by the importer as the Genlock. The device allows the user to add computer graphics to a home videotape. The Genlock synchronizes and combines the signals of a computer and a video camera or video cassette recorder (VCR). The pin connectors integrally extending from the Genlock plug in to the video ports located in the back of several models of Commodore Amiga computers. The device is connected to a VCR or video camera with cables. Using one of several software packages, the user constructs graphics over the home videos which are viewed on the computer monitor. A television receiver can be used as a second monitor. The Genlock is packaged for retail sale with cables and an instruction manual. ISSUE: Is the merchandise classified as an accessory to an automatic data processing (ADP) machine, in Heading 8473? LAW AND ANALYSIS: The Harmonized Tariff Schedule of the United States Annotated (HTSUSA) provides that the classification of articles is governed by the General Rules of Interpretation (GRI's). -2- GRI 1 states in pertinent part that "...classification shall be determined according to the terms of the headings and any relative section or chapter notes...". Heading 8473 in pertinent part describes accessories suitable for use solely or principally with machines of Heading 8471 (ADP machines). The Explanatory Notes to Heading 8473, p. 1304, provide that Heading 8473 accessories are "...interchangeable parts or devices designed to be mounted on a machine to adapt it for a particular operation, or to perform a particular service relative to the main function of the machine, or to increase its range of operations." The Genlock is mounted on several models of ADP machines to adapt it for the particular operation of constructing graphics over home video images. The Genlock increases the range of operations of ADP machines. In HQ Ruling 082930 (March 1, 1990), we held that a device which allowed a computer, with the proper software, to synchronize with audio or video tape was classified as an accessory of ADP machines in Heading 8473. The Genlock is described by Heading 8473 as an ADP accessory, and is classified in subheading 8473.30.40, HTSUSA. The Genlock is entered packaged for retail sale with insulated cables fitted with connectors and an instruction manual. The cables would separately be classifiable as electrical conductors in Heading 8544. The manuals would separately be classifiable as printed matter in Chapter 49. When entered packaged for retail sale with the Genlock, the cables and manuals are classified with the Genlock as a GRI 3(b) set. HOLDING: The Genlock, connector cables and instruction pamphlet entered packaged for retail sale are classified as accessories to ADP machines in subheading 8473.30.40, HTSUSA. Sincerely, John Durant, Director Commercial Rulings Division