Front Camera Module classification under Customs law held to fall under motor vehicle parts, not automatic control instruments.

Classification of an imported Front Camera Module turned on whether it was an automatic regulating or controlling instrument under Heading 9032 or a motor vehicle part under Heading 8708. Heading 9032 applies only where the imported goods themselves form part of a complete or incomplete automatic control system that measures a variable, compares it with a set value, and controls it through an actuating device; the module here contained only a camera and ECU, while the measuring sensors and actuating mechanisms were outside the consignment and part of the vehicle system. Classification had to be determined on the goods as imported, so the argument that the module and vehicle components formed one functional unit was rejected. The module was held classifiable under Heading 8708 as a motor vehicle part.

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Issues: Whether the imported Front Camera Module is classifiable under CTI 9032 89 90 as an automatic regulating or controlling instrument or apparatus, or under CTI 8708 99 00 as a motor vehicle part.

Analysis: Heading 9032, read with Chapter Note 7 to Chapter 90 and the HSN Explanatory Notes, applies only where the goods themselves form part of a complete or incomplete automatic control system that measures a variable, compares it with a desired value, and performs control through an actuating device. The imported module was found to contain only a camera and ECU, while the measuring sensors and actuating mechanisms necessary to close the control loop were external to the imported consignment and part of the vehicle system. The claim that the module and vehicle components together formed a functional unit was rejected because classification must be determined on the basis of the goods as imported. On the other hand, the module was found to be specifically designed for motor vehicles and excluded from Section XVII only if it fell within Chapter 90, which it did not.

Conclusion: The Front Camera Module is not classifiable under CTI 9032 89 90 and is classifiable under Heading 8708, specifically CTI 8708 99 00, in favour of Revenue.

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