CLA-2-84:OT:RR:NC:1:120
Ms. Linda Muller Cole International
3033 34th Avenue, N.E.
Calgary, Alberta T2P 3C2
RE: The tariff classification of an RFID tag reading system from Canada
Dear Ms. Muller: In your letter dated February 3, 2015 you requested a tariff classification ruling on behalf of your client, Intelliwave Technologies, Inc. The merchandise under consideration identified as the “Rover,” is an automated mobile radio frequency identification (RFID) tag reader used in the construction industry.
The Rover is composed of a microprocessor, an RFID reader with an RFID antenna, a GPS antenna, a Wi-Fi antenna and a cell/HSPA antenna, which are connected to each other with an Ethernet cable. The Rover calculates the positions of materials, equipment and personnel within a specified area. It is to be mounted on vehicles that move around the construction site in order to track the position of RFID tags and read the tag’s encrypted data. The Rover’s processor incorporates a cellular module (modem) that provides an internet connection, and syncs and updates a computer server’s database with the latest positions of the RFID tags. The Rover’s software determines the position of the RFID tags based upon the Rover’s current GPS location and RF signal strength received from the tags. These RFID tags contain a microchip with stored data and are attached to an antenna. The RFID reader, using its own antenna, sends radio waves into the air to interact with the tag’s antenna, to receive data from the tag. The reader converts the radio waves it receives from the tag into digital data and transmits it for processing by the servers, which are automatic data processing machines for Tariff purposes. The reader can read up to 1,400 tags per second and can store up to 65,000 tags.
The Rover RFID tag reader meets Note 5C to Chapter 84, Harmonized Tariff Schedule of the United States, (HTSUS), which defines the term "data processing units" for purposes of heading 8471:
(i) it is of a kind solely or principally used in an automatic data processing (ADP) system;
(ii) it is connectable to the central processing unit (CPU) either directly or through one or more other units; and
(iii) it is able to accept or deliver data in a form (codes or signals) that can be used by the system.
The applicable subheading for the Rover RFID tag reader will be 8471.60.9050, Harmonized Tariff Schedule of the United States (HTSUS), which provides for: Automatic data processing machines and units thereof;…: 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: [email protected].
Sincerely,
Gwenn Klein Kirschner
Director
National Commodity Specialist Division