CLA-2-84:OT:RR:NC:1:104

Ms. Lea M. Ford
John S. Connor, Inc.
799 Cromwell Park Drive
Glen Burnie, MD 21061

RE: The tariff classification of a minibar vending tray from China.

Dear Ms. Ford:

In your letter dated November 2, 2010, on behalf of Minibar North America, you requested a tariff classification ruling.

You describe the instant merchandise as a minibar tray. Minibars are used in locations such as hotel rooms and cruise ship staterooms. The in-room minibars store snacks and beverages and are connected via communication technology, such as co-axial cable, to a central computer. When the guest removes a drink or snack, the unit sends a signal to bill the guest room for the article consumed. The “Smart Tray” expands the product capacity of the minibar.

The Smart Tray sits on top of the minibar to which it is hooked up for billing purposes. The tray incorporates a sensor that is laminated with melamine or high pressure laminate. Smart Trays are available with 4, 8 and 12 sensors or as a single water sensor. As items are removed from the tray, i.e., sodas and snacks, a signal is sent via the communication system to automatically charge the guest for the item. If the tray is not hooked up directly to the minibar, it will not work. The Smart Tray cannot be used with anything but the minibar.

The applicable subheading for the separately imported Smart Tray will be 8476.90.0000, HTSUS, which provides for Automatic goods-vending machines (for example, postage stamp, cigarette, food or beverage machines), including money-changing machines; parts thereof: Parts. 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 Patricia O’Donnell at (646) 733-3011.

Sincerely,

Robert B. Swierupski
Director
National Commodity Specialist Division