The tariff classification of an external video capture device from Singapore

NY A89299 November 8, 1996 CLA-2-84:RR:NC:1:110 A89299 CATEGORY: Classification TARIFF NO.: 8471.80.9000; 8524.91.0030 Mr. Raymond Tsui Great World Customs Service 1305 Grandview Drive South San Francisco, CA 94080 RE: The tariff classification of an external video capture device from Singapore Dear Mr. Tsui: In your letter dated November 4, 1996, on behalf of AiTech International Corp., you requested a tariff classification ruling. The merchandise under consideration involves a model AiGotcha video capture device that connects to a personal computer and such video devices as camcorders and VCR's for the purpose of capturing images from a video source. Once the image is captured and converted into a computer file, the user then is able to manipulate it using graphic software. This device has the ability to capture images in 16.7 million colors and is a simple plug and play device that connects to the external parallel port. In its imported condition it appears to include the external hardware device, image capture software, cables and a user's manual. After capturing a video shot from a video source, the user can then use them for web page publishing, multimedia presentations, disk-based catalogs, personal photo albums, image databases, digital greeting cards, and newsletters. This video capture device appears to meet the definition of a set, noting GRI-3 (b). The essential character of this set would be exemplified by the video capture device. The video capture device would also meet the definition of a "unit" of an ADP system, noting Legal Note 5 (B) to Chapter 84 of the HTS. Although classifiable as a retail set, the software would be separately classifiable, noting Legal Note 6 to Chapter 85 of the HTS. The applicable subheading for the AiGotcha video capture device will be 8471.80.9000, Harmonized Tariff Schedule of the United States (HTS), which provides for other units of automatic data processing machines. The rate of duty will be 2.2 percent ad valorem. The applicable subheading for the image capture software will be 8524.91.0030, HTS, which provides for other recorded media, prepackaged software for automatic data processing machines, of a kind sold at retail. The rate of duty will be 5.8 cents per square meter of recording surface. 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 Art Brodbeck at 212-466-5490. Sincerely, Roger J. Silvestri Director National Commodity Specialist Division