CLA-2-84:S:N:N1:110 807080

Mr. John Hanson
Epson America, Inc.
20770 Madrona Avenue
Torrance, CA 90503-3777

RE: The tariff classification of an Intelligent Terminal from Japan.

Dear Mr. Hanson:

In your letter dated February 7, 1995, you requested a tariff classification ruling. The merchandise under consideration involves two models of Intelligent Terminals (IT-U950 and IT-U375) that are designed primarily for Point of Sale applications.

The Intelligent Terminal consists basically of a standard digital 486/33 processor unit that is mated with a POS printer on top. The processor unit appears to meet the definition of a digital processing unit as per LN 5 (A) to Chapter 84 of the HTS. The printer is a POS dot matrix printer connected to the computer by means of an internal cable, but can print out only on narrow type journal or cash register type paper.

The terminal/printer combination device is basically a composite machine that is designed primarily for POS applications in supermarkets, retail stores, hotels, and restaurants. This composite article is therefore designed to function wherever a cash register or transaction terminal is normally used. Along with special software which is added in the U.S. and either an optional scanner or keyboard, the unit can input data, either manually or automatically, and make a record of a transaction. Noting HQ Ruling letter 086121, this intelligent terminal would thus appear to meet the definition of a "cash register", as outlined in Explanatory Note 84.70 (C) to the HTS. Combined with a wide variety of accessories, this terminal will serve as a complete register accounting system for the POS market. The applicable subheading for the Intelligent Terminals will be 8470.50.0020, Harmonized Tariff Schedule of the United States (HTS), which provides for Point of Sale Terminals (Cash Registers). 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