## Facts

- JVC imported video camera recorders (camcorders) in 1992.
- The parties agreed the merchandise had two independent functions generally used together: a television camera and a video tape recorder.
- Customs classified the camcorders under HTSUS subheading 8525.30.00 (“Television cameras”), imposing a 4.2% ad valorem duty.
- JVC protested and challenged the classification in the Court of International Trade (CIT), arguing the goods should instead be classified under HTSUS headings 8543 or 8479 as machines/apparatus with “individual functions” not specified elsewhere.
- The CIT granted summary judgment for the government and denied JVC’s motion; JVC appealed.

## Issues

1. Whether multifunction camcorders were properly classified under HTSUS subheading 8525.30.00 as “television cameras,” rather than under residual headings 8543 or 8479 for machines/apparatus not specified elsewhere.
2. Whether prior Federal Circuit authority construing the predecessor TSUS tariff scheme controlled the classification outcome under the HTSUS.

## Decision

- The Federal Circuit affirmed the CIT’s grant of summary judgment to the government.
- The court held the camcorders were properly classified under HTSUS subheading 8525.30.00 (“Television cameras”).
- The court rejected classification under headings 8543 and 8479 because those provisions apply only when the article is not specified or included elsewhere.
- The court held the TSUS-era decision cited by JVC was not dispositive under the HTSUS.

## Legal Principles

- Tariff classification is governed first by GRI 1: classification according to the terms of the headings and any relevant section or chapter notes.
- A heading that expressly covers apparatus “whether or not incorporating” recording or reproducing components can include multifunction devices within that heading.
- Explanatory Notes, while not legally binding, are persuasive interpretive aids for HTSUS headings, particularly where they directly describe the type of merchandise at issue.
- Residual (“basket”) headings for machines/apparatus with “individual functions” not specified or included elsewhere do not apply when a more specific heading describes the goods.
- Prior classification decisions under the TSUS do not control when the HTSUS text and interpretive materials provide a different, more specific framework.

## Conclusion

The Federal Circuit held that camcorders combining a television camera and a video recorder fall within the HTSUS provision for “television cameras” because the heading’s text and interpretive materials contemplate such combined devices, thereby foreclosing resort to residual headings for unspecified machines or apparatus.


JVC Co. of Am. v. United States, 234 F.3d 1348 (Fed. Cir. 2000)