CLA-2-84:OT:RR:NC:N4 462
Scott Cassell
JAS Forwarding (USA) Inc.
6165 Barfield Road Atlanta, GA 30328
RE: The tariff classification of point of sale machines
Dear Mr. Cassell:
In your letter dated April 17, 2024, you requested a tariff classification ruling on behalf of your client, Block, Inc.
The merchandise in question, the “R12 Square Reader,” is a point of sale system (POS). It has the ability to accept and process various forms of payment, including chip cards, tap to pay via Near Field Communication (NFC), Google Pay, and Apple Pay. The R12 Square Reader supports Square’s various point of sale software and are compatible with Apple and Android phones and tablets.
Internally, the R12 includes two logic printed circuit boards, a payments board (SPE) and a main logic board (MLB). The SPE board controls payment processing functionality, including chip-card dip and tap NFC as well as some pass-through circuitry. The MLB manages power control, and user interfaces (LEDs), and control of communications between the connected phone or tablet. The outer shell of the unit is mainly made of post consumer recycled PC and ABS-polycarbonate and acrylonitrile butadiene styrene plastic.
The R12 Square Reader is an unfinished or incomplete cash register and possesses the character of a finished cash register because it includes built-in card readers and the ability to facilitate various types of payments. It is the opinion of this office that, in the imported condition, R12 Square Reader is an incomplete machine that hasthe predetermined end-use in and dedicated design for the POS terminals. They have the essential character of the complete or finished POS terminal, General Rule of Interpretation (GRI) (2)(a) noted.
The applicable subheading for the “R12 Square Reader,” point of sale system, will be 8470.50.0020, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Calculating machines…ticket-issuing machines and similar machines…cash registers: Cash registers: Point of sale terminals.” 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 at https://hts.usitc.gov/.
The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP.
This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection 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, please contact National Import Specialist Sandra Sary at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division