In NY Ruling N302431 (Feb. 5, 2019), U.S. Customs and Border Protection (CBP) discussed the tariff classification of a pet treat dispenser with a camera! The country of origin of the imported product was China. The pet dispenser consisted of an HD camera with night vision, a microphone and speaker, a treat tossing mechanism, and a natural bamboo cover.

The treat dispenser allowed pet owners to interact and monitor their pets remotely through an application on their smartphone or tablet. The camera captures video and transmits the video images to an app, where owners can watch remotely, but there is recording capability. However, the pet images can be recorded on a smart device where the app is downloaded. In reaching a ruling the decision, CBP determined that the main function of the treat dispenser was actually the camera function and not the treat dispensing function.

Therefore, CBP determined that the applicable subheading was 8525.80.3010 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: Other: Color”. The rate of duty will be 0.5 percent ad valorem.

Products of China classified under subheading 8525.80.3010, HTSUS, unless specifically excluded, are also subject to the additional 301 tariffs with a 10% ad valorem rate of duty (List 3). Accordingly, importers must report the Ch. 99 subheading (9903.88.03), in addition to subheading 8525.80.3010, HTSUS.