CLA-2-84:OT:RR:NC:N1:120
Mr. Serge Desalvo
Russell A. Farrow (US) Inc.
8053 East Bloomington Freeway, Ste. 400
Bloomington, MN 55420
RE: The tariff classification of card personalization machines from Malaysia
Dear Mr. Desalvo:
In your letter dated July 14, 2014, on behalf of Card Technology Corporation dba NBS Technologies, you requested a tariff classification ruling.
The subject merchandise, based on the submitted information, consists of several card personalization machines: the ImageMaster S-18, the ImageMaster D-40, and the Advantage 2000 series (the M2 and the M3), which are composite machines used to personalize various types of plastic cards.
The ImageMaster S-18 is a thermal printing and encoding machine, which can print and encode up to 1,800 single-sided plastic cards, per hour, measuring about 2.125 inches by 3.375 inches. It incorporates an optical magnetic encoder, a printing foil, an output hopper, an input hopper, a printhead, a switch panel, a reject tray, a cleaning tape, and a liquid crystal display.
The ImageMaster D-40 is a thermal printing and encoding machine, which can print and encode up to 4,000 single-sided plastic cards per hour and 1,500 dual-sided plastic cards per hour, with all the cards measuring about 2.125 inches by 3.375 inches. It incorporates an optical magnetic encoder, a printing foil, an output hopper, an input hopper, a printhead, a switch panel, a reject tray, a cleaning tape, a card flipper, and a liquid crystal display.
The Advantage 2000 series (the M2 and the M3) are thermal printing, embossing and encoding machines which can print, emboss, and encode large volumes of plastic cards, as well as program smart cards. Each features a keyboard for manual data entry, a 110-character embossing wheel, an auto-feed input hopper, an auto-unload stacker, a fully functional control panel, card counters, an RS-232 serial communication interface, online system software, an online data analyzer, and a liquid crystal display. The M2 can print up to 280 cards per hour, while the M3 can print up to 350 cards per hour.
These devices, which are principally used with automatic data processing (ADP) machines via an RS-232 connection or an Ethernet cable, retrieve information from databases within a variety of host computers, including personal computers running Microsoft Windows, Windows 7, XP, AS400 and Linux/Unix systems. These ADP machines provide the layout of information from the databases that personalize the cards for financial, membership, loyalty and telephone card applications in bureau, gaming and leisure production environments.
In regard to the ImageMaster S-18, the ImageMaster D-40, and the Advantage 2000 series (the M2 and the M3), the data retrieved is not only for printing personalized information onto the plastic card but also for encoding data onto the magnetic stripe of the card, noting that the Advantage 2000 series (the M2 and the M3) can also retrieve data for embossing information onto the plastic card.
Each of the above machines meet the following requirements of Note 5(C) to Chapter 84, Harmonized Tariff Schedule of the United States (HTSUS), as a unit of an ADP system: It is of a kind solely or principally used in an ADP system; it is connectable to the central processing unit (CPU) either directly or through one or more other units; and it is able to accept or deliver data in a form (codes or signals) which can be used by the system.
Further, it has been determined that the principal function of these machines, which are considered to be composite machines for tariff classification purposes, is being performed by their encoding function.
The applicable subheading for the ImageMaster S-18, the ImageMaster D-40, and the Advantage 2000 series (the M2 and the M3) will be 8471.80.9000, HTSUS, which provides for Automatic data processing machines and units thereof…: Other units of automatic data processing machines: 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 documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist Denise Faingar at [email protected].
Sincerely,
Gwenn Klein Kirschner
Director
National Commodity Specialist Division