HQ 082559: Panasonic WG-R2 Two-Way Still-Picture Transceiver

Native CBP ruling rendition. Applicability is fact-specific; modification/revocation relationships and original publisher date are retained. Publisher sentinel year0001 means unknown date, not a historical legal adoption.

                            HQ 082559

                       September 25, 1989


CLA-2 CO:R:C:G   082559   JMH

CATEGORY:  Classification

TARIFF NO.:  8517.81.20

Mr. William R. Palle
Panasonic Industrial Company
One Panasonic Way
Secaucus, New Jersey  07094

RE:  Panasonic WG-R2 Two-Way Still-Picture Transceiver

Dear Mr. Palle:

     Your request of May 10, 1988, for a ruling on the
classification of the Panasonic WG-R2 Two-Way Still-Picture
Transceiver has been referred to this office for a reply.

FACTS:

     The WG-R2 Two-Way Still-Picture Transceiver (WG-R2) connects
to any modular telephone.  It consists of a still-picture video
camera incorporated into a black and white television monitor.
The unit allows the user to transmit a still-picture image --
either of the sender or of an object in the sender's vicinity --
to a receiving party.  The receiving party must have a compatible
unit.  The WG-R2 is not imported with a modular telephone, but
does require connection to the same in order to function.

ISSUE:

     What is the proper classification of the WG-R2 under the
Harmonized Tariff Schedule of the United States?

LAW AND ANALYSIS:

     Classification of merchandise under the HTSUSA is governed
by the General Rules of Interpretation (GRI's).  GRI 1 states in
part that "for legal purposes, classification shall be determined
according to the terms of the headings and any relative section
or chapter notes..."

     It is the opinion of this office that heading 8517, HTSUSA,
is the appropriate classification.  Heading 8517 describes
                               -2-

 "Electrical apparatus of line telephony...including such
apparatus for carrier-current line systems; part thereof..."
Since WG-R2 is an electrical appliance to be used with a modular
telephone system, it fits within this heading.

HOLDING:

     The proper classification for the Panasonic WG-R2 Two-Way
Still-Picture Transceiver is under heading 8517.81.20, HTSUSA.
The rate of duty is 8.5 percent ad valorem.

                              Sincerely,



                              John Durant, Director
                              Commercial Rulings Division