CBP Classifies Doorbell Cameras as TV Cameras in 3 Rulings

Digital security cameras mounted as doorbells fall under the Harmonized Tariff Schedule heading governing TV cameras and video camera recorders, according to three separate CBP rulings issued June 21 and publicly released last week.

In all three cases, CBP determined that the digital security cameras were classifiable under HTS heading 8525, and specifically under subheading 8525.89.30, 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, digital cameras and video camera recorders: Other: Television cameras: Other.”

The three rulings were H332743, covering Amazon's Ring Video Doorbell devices, a home security monitoring device consisting of a doorbell, camera, sensors, speaker and microphone; H331779, on a digital doorbell and home security monitoring security camera called Blink Video Doorbell White and Blink Video Doorbell Black Plus Sync Module 2 and consisting of a doorbell, camera, sensors, speaker and microphone with an analog/digital converter and wireless output mechanism that streams video to the cloud for viewing on external devices; and H324237, which explored the Floodlight Camera Wired Plus with motion-activated 1080p high definition video using “snapshot capture” technology. The camera has LED floodlights, 110-decibel siren alarm and a built-in microphone and speakers allowing for two-way talk.

In all three cases, CBP noted that the images that the cameras took were saved externally, such as to the virtual cloud for memory storage, and not within the device itself. The images also are meant to be transmitted to locations outside of the camera versus within the camera, the agency determined.

These qualities liken the security cameras to television cameras, according to CBP.

For Amazon’s Ring devices, CBP said: “The subject camera can be configured to provide a variety of images in terms of the length of video and intervals of still frame images via the ‘Snapshot Capture’ feature for desired viewing in the [Ring] mobile app. Likewise, the camera features [Electrically Erasable Programmable Read-Only Memory] EEPROM and flash memory to facilitate the transmission of content to the cloud and guard against losing content when the camera is offline. All of these features are in furtherance of the camera capturing and transmitting video images to locations outside the camera, in the manner of a surveillance camera described in EN 85.25(B), supra, and not for the internal recordation of images for direct retrieval by the user.”

For the Blink video doorbells, CBP said that though Amazon.com Services, LLC “submits that the ‘Sync Module’ may be used to store the camera’s still and moving images, the 'Synch Module' is a local USB drive (not internal) and is not sold with all versions of the [Blink video doorbell] camera. Based on the foregoing, the subject camera does not record images onto an internal storage device or onto media and, therefore, classification is not proper under subheading 8525.80.40, HTSUS (2021).”

Furthermore, the subject camera “can be configured to provide a variety of images in terms of the length of video and intervals of still frame images via the ‘Snapshot Capture’ feature for desired viewing in the mobile app. Likewise, the camera features RAM and flash memory to facilitate the transmission of content to the cloud and guard against losing content when the camera is offline,” CBP continued. “All of these features are in furtherance of the camera capturing and transmitting video images to locations outside the camera, in the manner of a surveillance camera described in EN 85.25(B), supra, and not for the internal recordation of images for direct retrieval by the user.”

And for the Floodlight Camera Wired Plus, CBP said that “the subject camera does not feature an SD slot or, as was the case with the camera at issue in Sony, user accessible internal memory or other removeable memory. Moreover, the subject camera erases (overwrites) all captured images when memory reaches capacity or within 24 hours of upload to the cloud. Based on the foregoing, the subject camera does not record images onto an internal storage device or onto media and, therefore, classification is not proper under subheading 8525.89.40, HTSUS.”

Furthermore, the “subject camera can be configured to provide a variety of images in terms of the length of video and intervals of still frame images via the ‘Snapshot Capture’ feature for desired viewing in the [Ring] mobile app. Likewise, the camera features EEPROM and flash memory to facilitate the transmission of content to the cloud and guard against losing content when the camera is offline. All of these features are in furtherance of the camera capturing and transmitting video images to locations outside the camera, in the manner of a surveillance camera described in EN 85.25(B), supra, and not for the internal recordation of images for direct retrieval by the user. As such, the subject camera is properly classified under subheading 8525.89.30, HTSUS, which provides for television cameras.”