CLA-2-84:OT:RR:E:NC:1:120

Mr. Juan Carlos Abello

RE: The tariff classification of a portable RFID reader from Italy

Dear Mr. Abello:

In your letter dated June 23, 2009 you requested a tariff classification ruling.

The merchandise under consideration is the RFIDat reader used to track employee mobility in various industries. It is a portable radio frequency identification reader (RFID) that measures 2.3 inches x 1.7 inches x .6 inches. It is equipped with an LCD display and an LED button.

The RFIDat reads the RFID transponder (imported separately) storing the identification number of the transponder enabling the reader to store the ID in its memory, recording the date and time of the event. It can read up to 3,000 readings of transponders and can store up to 8,000 transactions on its internal flash memory. It is powered by an internal rechargeable battery and uses the RFIDock docking station (imported separately) to communicate and transfer data to a computer. The software downloaded to a computer registers the readers with ID data, configures the date and time, and programs it to read tags one-by one, simultaneously, or from other readers. The software translates the transmitted data to determine work flow, attendance, labor time and productivity.

When the reader’s LED button is pressed, the reader searches for a transponder contained in a coin sized tag or detection points. The transponder can be inserted into a component, placed in a car, a work order, a door, a box, or placed in a specific work location. Once found the unit alerts the user; collects and stores the activity. It records the alphanumeric unique code programmed in each transponder, which incorporates all the relative data for the machine, location, client and employee. The reader’s LCD displays the user’s name, ID number, date and time, number of readings from other RFID portable readers and indicates the battery and charge level.

The RFIDat is principally or solely used with an automatic data processing (ADP) machine, and meets Note 5 (c) of Chapter 84, Harmonized Tariff Schedule of the United States (HTSUS). The applicable subheading for the RFIDat, will be 8471.60.9050, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Magnetic or optical readers…: Input or output units, whether or not containing storage units in the same housing: Other: Other: Other. The rate of duty will be Free.

Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.

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

A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist Denise Faingar at (646) 733-3010.

Sincerely,

Robert B. Swierupski
Director
National Commodity Specialist Division