NY 855636
Aug 24 1990

CLA-2-84:S:N:N1:110 855636

Mr. Irving W. Smith, Jr.
George R. Tuttle
1331 Pennsylvania Avenue, N.W., Suite 905
Washington, D.C. 20004

RE: The tariff classification of printers imported with transaction terminals from Taiwan.

Dear Mr. Smith:

In your letter dated August 15, 1990, on behalf of Verifone Inc., you requested a tariff classification ruling. The merchandise under consideration involves slip or roll printers that are imported with point-of-sale terminals such as models Zon Jr. XL and Tranz 330. The Zon Jr. XL and the Tranz 330 are used by businesses to record sales transactions as they occur. The sales data is entered manually through a keyboard or automatically by using an incorporated card reader. Once the sales information is entered, the terminals are able to record inventory information, the amounts of each sale, and the total of all sales. Model printers such as the Verifone Printer 600, Verifone Printer 150, Verifone Printer 250, and Verifone Printer 500 are used to perform automated printing of customer receipts.

The four models of printers are designed specifically to function with the Verifone point-of-sale terminals. The Printer 600 uses single-ply thermal paper and provides a hard copy sales receipt for the customer. Printer 150 is a 7-PIN shuttle impact dot matrix printer which provides low-cost slip printing up to 42 columns wide, and gives a complete audit trail summarizing the day's transaction. Printer 250 is a 7-PIN dot matrix printer which can produce 2- or 3-part sales receipts and a summary of the transactions for that day. Printer 500 is a 4-function printer that produces roll-slip and validation receipts as well as summary journal receipts.

The importation of the Verifone point-of-sale terminals and the printers provide the ability to visually display and print the results of sales transactions which are functions normally found in most cash registers. Noting Legal Note 3 for Section 16 of HTS, composite machines consisting of two or more machines fitted together to form a whole and other machines adapted for the purpose of performing two or more complementary or alternative functions are to be classified as if consisting only of that component or as being that machine which performs the principal function. The principal function of this composite machine is the cash register function, and the printing of sales receipts is a complimentary or alternative function.

The applicable subheading for the point-of-sale terminals and printers imported together will be 8470.50.0020, Harmonized Tariff Schedule of the United States (HTS), which provides for cash registers and similar machines, incorporating a calculating device. The rate of duty will be free.

This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177).

A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction.

Sincerely,

Jean F. Maguire
Area Director
New York Seaport