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JVC Co. of America v. United States
United States Court of Appeals for the Federal Circuit
234 F.3d 1348 (2000)
JVC Company of America (JVC) (plaintiff) imported video camera recorders known as camcorders. The camcorders were electrical machines with two independent functions that worked together: a television camera and a videotape recorder. The United States Customs Service (Customs) (defendant) classified the camcorders under Harmonized Tariff Schedule of the United States (HTSUS) section 8525.30.00 as “television cameras,” which were dutiable at a rate of 4.2 percent ad valorem (i.e., 4.2 percent of the value of the imported item). The explanatory notes to heading 8525 expressly provided that the heading covered television cameras and portable cameras with or without a built-in video recorder. The McGraw-Hill Encyclopedia of Science & Technology’s entry on television cameras indicated that television cameras could be portable and combined with a detachable or built-in video recorder to form a camcorder. JVC challenged Customs’ classification, asserting that the camcorders should have been classified under HTSUS section 8543.80.90 or 8479.89.90, which were dutiable at lower rates. Heading 8543 covered electrical machines and apparatus having individual functions, and heading 8479 covered machines and mechanical appliances having individual functions. The Court of International Trade upheld the classification under 8525.30.00, and JVC appealed to the United States Court of Appeals for the Federal Circuit.
Rule of Law
Holding and Reasoning (Lourie, J.)
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