CBP Affirms Previous Ruling That Teleprompter Bases Aren't 'Integral' to Teleprompter
CBP recently held that a teleprompter base is properly classified as an article of aluminum rather than as a part of an electrical machine, upholding an August 2022 ruling after an importer requested reconsideration.
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Issued last month, the ruling said Ikan International’s teleprompter base is properly classified under subheading 7616.99.51 because the base isn't integral to the teleprompter. Subheading 7616.99.51 accounts for “Other articles of aluminum: Other: Other: Other.”
Ikan had asked CBP to reconsider its previous ruling so that the teleprompter base could be reclassified under subheading 8543.90.88, meaning as a “part” of an electrical machine with an individual function.
The teleprompter base, Model PT4200, is used in professional digital photography and videography. The base, which comes unassembled, consists of an aluminum frame, base, frame holder, camera mount, polyester hood, carbon fiber rods, steel screws and hex tools. The metal in the teleprompter base predominates by bulk and weight, thus providing the essential character of the teleprompter base, according to CBP.
CBP previously ruled against the teleprompter base being a “part” because the teleprompter can still function without it, so it isn't an “integral” part of the teleprompter even though the base’s sole purpose is to support the teleprompter.
When reviewing Ikan’s reclassification request, CBP found that past court decisions held that merchandise such as a typewriter desk or a piano bench aren't considered integral components even though the supports may be essential to the proper use of the main merchandise.
“Just as the typewriter desk’s role was to mount to the typewriter in Willoughby, and just as the ‘rigid supports’ merely attached to and supported the stationary engine in that case, the subject teleprompter base’s function is to mount and support the teleprompter’s components -- a function which, alone, does not transform the base into a ‘part’ under the HTSUS,” CBP said, affirming NY N327400.
The importer "failed to demonstrate how, without the teleprompter base, the teleprompter’s components lose their functioning and essential characteristics. The user-provided video camera (by virtue of it being ‘user-provided’) would still function as a video camera without the teleprompter base and retain its characteristics as a video camera. Likewise, the monitor would still be a monitor without the base and could still display text without the base,” CBP said.
CBP continued: “Like the typewriter desk, piano bench, and rigid supports in Willoughby, the teleprompter base here may be ‘essential to the proper use’ of its associated articles, but the associated articles retain their functions and essential characteristics without the support. The most that can be said is that the teleprompter base and its associated articles are designed to be used together and are chiefly so used.”