Bayer International Trade Services Corporation
651 Colliers Way, Suite 414
Weirton, WV 26062
RE: The tariff classification of the Certegra Connect.CT Workstation from Taiwan
Dear Mr. Johnsen:
In your letter dated April 7, 2017 you requested a tariff classification ruling on behalf of your client, Bayer Healthcare, LLC.
The merchandise under consideration is identified as the Certegra Connect.CT Workstation (Certegra) which consists of an all-in-one personal computer (PC), a mounting assembly and base, an Ethernet cable, and a power adapter. The Certegra PC is described as an enclosure which is equipped with the CPU, memory, disk storage, a 15.6” LCD display, and a touchscreen overlay. While the Certegra PC runs on the Windows Operating System, you state that features and functionality of the workstation have been restricted and the user does not have the ability to add/remove application of their choosing, or to perform certain data processing functions. Therefore, we do not consider the Certegra PC to be an automatic data processing machine in accordance with Chapter 84 Note 5, Harmonized Tariff Schedule of the United States (HTSUS).
The Certegra workstation is used in conjunction with a contrast media injection system and a scanner (e.g., computerized tomography (CT) scanner) that manages/controls the injector and allows the user to interface with a hospital’s data network for managing patient data and controlling doses. These very specific functions are achieved through the use of dedicated software applications that you refer to as the “Point of Care” and the “Informatics/Connect CT solution” programs. While you state the Certegra workstation is typically part of the entire injector system, this ruling request is limited to only the Certegra workstation and its mounting base assembly.
In your request, you suggest the Certegra Workstation is correctly classified in subheading 8517.62.0050, HTSUS, which provides for “Telephone sets…; other apparatus for the transmission or reception of voice, images or other data…: Other apparatus for transmission or reception of voice, images or other data…: Machines for the reception, conversion and transmission or regeneration of voice, images or other data…: Other.” However, the Certegra Workstation is a customized processing unit that is designed to run specific programs for a specialized purpose, which is to manage and control a medical injection unit/machine. The functions of running the Point of Care medical program and the ability to control/monitor various aspects of the injector machine propel this unit beyond the intended scope of heading 8517. As such, heading 8517 is not appropriate.
The applicable subheading for the Certegra Workstation will be 8543.70.9960, HTSUS, which provides for “Electrical machines and apparatus, having individual functions, not specified or included elsewhere in this chapter…: Other machines and apparatus: Other: Other: Other: Other.” The rate of duty will be 2.6% ad valorem.
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 https://hts.usitc.gov/current.
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 Karl Moosbrugger at email@example.com.
Steven A. Mack
National Commodity Specialist Division