CLA-2-84:RR:NC:1:110 K86497

Mr. Barry Stark
Hitachi America, Ltd.
50 Prospect Avenue
Tarrytown, NY 10591-4698

RE: The tariff classification of a Cassette Board from Japan.

Dear Mr. Stark:

In your letter dated May 26, 2004, on behalf of Hitachi America, Ltd. you requested a tariff classification ruling.

The merchandise under consideration is Part No. M7601536A “Cassette Board.” The Cassette Board is part of Hitachi’s Cash Module (HCM). The HCMs are used in conjunction with Automated Teller Machines. These HCM modules include the Cash Acceptance Box (AB) and the Cash Recycling Box (RB) and are the main cash-handling units within an ATM. The cassette board is a memory board specially designed for use with the HCMs. This cassette board stores the information needed for the HCM modules to function properly within the ATM. The HCM performs such task as counting and validating banknotes deposited by customers, storing and dispensing banknotes, etc. Your request suggests that the cassette board be classified in subheading 8524.91.0070 as recorded media. Although the board uses flash memory, it is not a memory card that can be used in various applications such as game machines, cameras, etc. It is not portable and does not have the character of recorded media.

The applicable subheading for Part No. M7601536A, Cassette Board will be 8473.40.1000, Harmonized Tariff Schedule of the United States (HTS), which provides for “Parts and accessories…Parts and accessories of the machines of heading 8472: Printed circuit assemblies for automatic teller machines of subheading 8472.90.10.” The general rate of duty will be free.

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 Eileen S. Kaplan at 646-733-3016.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division