CLA-2-84:OT:RR:E:NC:1:120

Mr. Juan Carlos Abello
Zeitgroup
1395 Brickell Avenue
Suite 800
Miami, FL 33137

RE: The tariff classification of a docking station from Italy.

Dear Mr. Abello:

In your letter dated July 24, 2009, you requested a tariff classification ruling.

The merchandise under consideration is the RFIDock-M. It is a docking station for the RFIDat portable RFID reader, an automatic data processing (ADP) input unit which is imported separately. The RFIDock-M is designed to connect to a freely programmable personal computer through its USB (universal serial bus) connection, its RS-232 serial connection, or wirelessly through RF (radio frequency). It effects the interconnection of the freely programmable computer’s CPU (central processing unit) to the RFIDat portable RFID reader, so that the data stored on the reader can be uploaded to and manipulated by the computer, and the computer can program the individual RFID reader. In use, the RFIDat reader is placed in the dock, or communicates wirelessly via RF connection, and the time/attendance data stored on the reader is downloaded to the RFIDock-M. The RFIDock-M features circular flash memory capable of storing up to 16,000 transactions. The RFIDock-M then communicates with the CPU of the connected computer, and transfers the data to the computer. The RFIDock-M is also the medium through which the connected computer communicates with individual RFIDat readers. The computer, via the RFIDock-M, registers the readers with ID data, configures the date and time, and programs it to read tags one-by one, simultaneously, or from other readers. Additionally, the RFIDock-M charges the battery of the inserted RFIDat reader, using power drawn from either the USB connection or from a wall socket via the dock’s 12 V (volt) power adapter cable. As a composite machine, the charging function is subsidiary to the control or adapter functions.

The RFIDock-M meets the requirements of Note 5(C) to Chapter 84, Harmonized Tariff Schedule of the United States (HTSUS). It is solely or principally used with an ADP system; it is connectable to the central processing unit directly or through one or more other units; and is able to accept or deliver data in a form which can be used by the system.

The applicable subheading for the RFIDock-M will be 8471.80.1000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Automatic data processing machines and units thereof…Other units of automatic data processing machines: Control or adapter units. 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 (646) 733-3010.

Sincerely,

Robert B. Swierupski
Director
National Commodity Specialist Division