H335012

HQ H335012 October 2, 2026 OT:RR:CTF:CPMMA H335012 LLO CATEGORY: Classification TARIFF No.: 9620.00.70 Ms. Ewa Szczepanski Casio America, Inc. 570 Mt. Pleasant Avenue Dover, NJ 07801 Re: Request for Binding Ruling; Classification of Casio Colpocamera Stand model number CST-100M Dear Ms. Szczepanski: This is in response to your request, on behalf of Casio America, Inc., for a binding ruling regarding the classification of the Casio Colpocamera folding camera stand, model number CST-100M, under the Harmonized Tariff Schedule of the United States (HTSUS). The original ruling request was made on June 22, 2023, to the National Commodity Specialist Division (NCSD), New York, and was assigned New York Ruling case number (NY) N333652, which requested additional information from you and was closed by the NCSD. On or about September 21, 2023, you resubmitted the ruling request to the NCSD which in turn forwarded the request to this office for decision. Our ruling is set forth below. FACTS: The Casio Colpocamera camera stand, model number CST-100M, is a folding, five-legged stand on casters that has a counterweighted, moveable arm to which Casio’s 1 Colpocamera can be mounted. Hand grips, the adjustable arm and casters enable medical professionals to situate the camera in optimal position to observe and capture images of colposcopies. You indicate that the country of origin is Japan. The 1 The Colpocamera consists of a complementary metal oxide semiconductor (CMOS) image sensor, lens, flash memory, a microphone, a speaker, an liquid crystal display (LED) light source fitted with green and polarizing filters, and a Wi-Fi (wireless LAN) component in one housing with a 3” touch-sensitive LCD display/monitor, a power button, an EV button (brightness adjustment), a shutter, a zoom button, a mode button, a play button, a battery compartment, a memory card slot, a USB port, an HDMI port, a DC jack, and a tripod mount (camera stand mounting hole). The camera can shoot still images and videos and record them onto both internal memory and an SD card. dimensions of the folded stand are 513 millimeters (mm) in diameter and 924 mm in height. The stand’s arm extends to approximately 300 mm in diameter. The stand is made primarily of aluminum and weighs 13.3 kilograms (29.3 pounds). You indicate that the main function of the stand is to provide stability for the camera during its use by a medical professional. This specially designed stand also allows for smooth and precise camera movement and easy positioning during observation and use. The stand is used to stabilize the camera, allowing the user to capture images without having to handle the Colpocamera and to avoid unintended movements and resultant unclear images. This stand is similar in design and use to a tripod, but with five legs, which stabilize the Colpocamera and eliminate movement to enhance image quality. Once the stand is in position, it remains in place until repositioned by the user. ISSUE: Whether the instant camera stand is classified in heading 9006, HTSUS as photographic (other than cinematographic) cameras; photographic flashlight apparatus and flashbulbs other than discharge lamps of heading 8539; parts and accessories thereof; or in heading 9620, HTSUS, as monopods, bipods, tripods and similar articles: of aluminum. LAW AND ANALYSIS: Merchandise is classifiable under the HTSUS in accordance with the General Rules of Interpretation (GRIs). GRI 1 provides that classification shall be determined according to the terms of the headings and any relative Section or Chapter Notes. In the 2 event that the goods cannot be classified solely on the basis of GRI 1, and if the headings or notes do not require otherwise, the remaining GRIs 2 through 6 may then be applied in order. The HTSUS provisions under consideration are as follows: 9006 Photographic (other than cinematographic) cameras; photographic flashlight apparatus and flashbulbs other than discharge lamps of heading 8539; parts and accessories thereof: Parts and accessories: 9006.91.00 For cameras. * * * * 9620.00 Monopods, bipods, tripods and similar articles: 9620.00.70 Of aluminum The Harmonized Commodity Description and Coding System Explanatory Notes (ENs) constitute the official interpretation of the Harmonized System at the international level. While neither legally binding nor dispositive, the ENs provide a commentary on the scope of each heading of the HTSUS and are generally indicative of the proper interpretation of these headings at the international level. See T.D. 89-80, 54 Fed. Reg. 35127, 35128 (August 23, 1989). The Explanatory Note to Chapter 90 provides in pertinent part that: 1. – This Chapter does not cover: (l) Monopods, bipods, tripods and similar articles, of heading 96.20[.] The Explanatory Note to Heading 90.06 provides in pertinent part as follows: Parts and Accessories … [M]onopods, bipods, tripods and similar articles are, however, excluded (heading 96.20). (Emphasis in the original.) Legal Notes 1(f) and 1(k) to Chapter 96 provide as follows: 1.- This Chapter does not cover: * * * * (f) Articles of chapter 90; * * * * 2 [.] (k) Articles of chapter 94 (for example, furniture) The General Explanatory Note to Chapter 96 provides, in pertinent part, as follows: 2 Note 1(m) to Chapter 94 similarly excludes “monopods, bipods, tripods and similar articles (heading 96.20).” 3 This heading covers monopods, bipods, tripods and similar articles, which are used as support for cameras, video cameras, precision instruments, etc., to reduce random movements. They may be extendable and are usually portable and may be equipped with a quick release device or head for easy mounting and release of the apparatus or instrument they support. These articles can be made of any material, e.g., wood, aluminum, carbon or a combination thereof. A monopod is a one-legged support, sometimes called a “unipod”. A bipod is a two-legged support for providing stability along two axes of motion. A tripod is a three-legged stand, which provides significant stability for the device it supports. For the purpose of this heading, the expression “similar articles” refers to devices with four or more legs, which have the same function as monopods, bipods and tripods in reducing random movements. You suggest classification of the instant merchandise in heading 9006, HTSUS, as parts and accessories of photographic (other than cinematographic) cameras; photographic flashlight apparatus and flashbulbs other than discharge lamps of heading 8539. The user’s manual and other advertising material provided indicate that the 3 Colpocamera is a sophisticated digital camera for diagnostic use . The Colpocamera uses memory cards and flash memory for purposes of image recording and retention as opposed to photographic film. The subheading that you have suggested provides for parts and accessories for film cameras but not for digital cameras. See NY N267989, dated September 22, 2015. It should be noted that “[p]hotographic and cinematographic cameras of Chapter 90 4 Since the Colpocamera does not expose images onto photographic film of Chapter 37.” expose images onto photographic film but rather uses memory cards and flash memory for purposes of image capture and retention, the Colpocamera is not a camera that falls to be classified under Chapter 90 of the HTSUS. As such, the subject merchandise is precluded from being classified as a part or an accessory under heading 9006, HTSUS. Finally, Chapter 90 Note 1(l), HTSUS, plainly states that the chapter does not cover monopods, bipods, tripods or similar articles of heading 9620, HTSUS. The ENs to heading 9620, HTSUS, indicate that the heading includes “monopods, bipods, tripods and similar articles, which are used as support for cameras, video cameras, precision instruments, etc., to reduce random movements.” The terms “monopod, bipod, and tripod” are defined in online lexicographic sources as follows: Merriam-Webster (Last visited Se

Merchandise is classifiable under the HTSUS in accordance with the General Rules of Interpretation (GRIs). GRI 1 provides that classification shall be determined according to the terms of the headings and any relative Section or Chapter Notes. In the 2
event that the goods cannot be classified solely on the basis of GRI 1, and if the headings or notes do not require otherwise, the remaining GRIs 2 through 6 may then be applied in order. The HTSUS provisions under consideration are as follows: 9006 Photographic (other than cinematographic) cameras; photographic flashlight apparatus and flashbulbs other than discharge lamps of heading 8539; parts and accessories thereof: Parts and accessories: 9006.91.00 For cameras. * * * * 9620.00 Monopods, bipods, tripods and similar articles: 9620.00.70 Of aluminum The Harmonized Commodity Description and Coding System Explanatory Notes (ENs) constitute the official interpretation of the Harmonized System at the international level. While neither legally binding nor dispositive, the ENs provide a commentary on the scope of each heading of the HTSUS and are generally indicative of the proper interpretation of these headings at the international level. See T.D. 89-80, 54 Fed. Reg. 35127, 35128 (August 23, 1989). The Explanatory Note to Chapter 90 provides in pertinent part that: 1. – This Chapter does not cover: (l) Monopods, bipods, tripods and similar articles, of heading 96.20[.] The Explanatory Note to Heading 90.06 provides in pertinent part as follows: Parts and Accessories … [M]onopods, bipods, tripods and similar articles are, however, excluded (heading 96.20). (Emphasis in the original.) Legal Notes 1(f) and 1(k) to Chapter 96 provide as follows: 1.- This Chapter does not cover: * * * * (f) Articles of chapter 90; * * * * 2 [.] (k) Articles of chapter 94 (for example, furniture) The General Explanatory Note to Chapter 96 provides, in pertinent part, as follows: 2 Note 1(m) to Chapter 94 similarly excludes “monopods, bipods,