CLA-2-84:RR:NC:1:110 D81084
Mr. Craig M. Schau
Emery Customs Brokers
6940A Engle Road
Middleburg Heights, OH 44130
RE: The tariff classification of Electronic Key Card Entry
Device System Components from Italy.
Dear Mr. Schau:
In your letter dated August 3, 1998, on behalf of Cisa
Security Products, you requested a tariff classification ruling.
The merchandise under consideration involves components that
are part of a security key card system that are typically used
with keyless card security systems commonly found in hotels for
room entry service.
The following components represent the imported portion of
this system: Card Key Encoder unit; Hand-held Interrogator; Card
Key reader; Aluminum and steel handle & facia; and Brass handle
and facia plate.
The Card Key encoder unit is used to encode the surface of
the card key, store the data, and recall and display individual
location information. The unit houses a keyboard, an LCD
display, microprocessor, and a minimum of 251k RAM that is
upgradeable. It stores the processing program, is programmed by
the user's requirements, and encrypts the key cards with
particular data that is obtained by the software. The principal
function of this device appears to be for transcribing data onto
data media in coded form, and would thus fall under the Part 2
provision of heading 8471. Please note HQ ruling 957416 of
6/20/95 that involved similar merchandise.
The Hand-held Interrogator is a portable data recovery unit
that is used to download individual entrance location information
from the card readers attached to the entrance doors. It is
battery operated and reads the encoded data record of key card
swipes. The user simply connects the Interrogator to the card
key reader on the door by a cable and transfers the electronic
data in the form of digital information, to the Interrogator.
The Door handle lever and exterior facia covers come in two
varieties: aluminum and brass. They consist of a door handle
lever and casing cover that houses the hand-held interrogator.
They do not contain the mechanical lock assembly.
The applicable subheading for the Card Key Encoder unit and
the Hand-held Interrogator will be 8471.90.0000, Harmonized
Tariff Schedule of the United States (HTS), which provides for
other machines for transcribing data onto data media in coded
form and machines for processing such data, not elsewhere
specified or included. The rate of duty will be free.
The applicable subheading for the aluminum and steel handle &
facia will be 8302.41.6045, HTS, which provides for other
articles of iron or steel, of aluminum or of zinc, suitable for
interior or exterior doors. The rate of duty will be 4.3 percent
ad valorem.
The applicable subheading for the brass handle and facia
plate will be 8302.41.9045, HTS, which provides for other
articles of base metal, suitable for interior or exterior doors.
Regarding the classification of the card key reader device,
please provide a sample of this device, since we are unable to
rule on this article for lack of a better description and what it
specifically incorporates.
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 Art
Brodbeck at 212-466-5490.
Sincerely,
Robert B. Swierupski
Director,
National Commodity
Specialist Division