CLA-2-84:OT:RR:NC:N2:220
Robert Liang
West One Products LLC
8301 Ram Ridge Road
Fort Worth, TX 76137
RE: The tariff classification of the Multi-Touch Monitor from Taiwan
Dear Mr. Liang:
In your letter dated January 7, 2025, you requested a tariff classification ruling.
The merchandise under consideration is identified as the 55" Multi-Touch Monitor for Computer Systems, Model 55MTM-2500B, which is described as a touchscreen LED display monitor having a capacitive touch overlay, an input/output terminal with USB, Display Port, VGA, and HDMI sockets, and internal speakers. Based on the information provided, the monitors are designed to be principally used with automatic data processing (ADP) machines.
The General Rules of Interpretation (GRIs) to the Harmonized Tariff Schedule of the United States (HTSUS) govern the classification of goods in the tariff schedule. GRI-1 states, in pertinent part, that "for legal purposes, classification shall be determined according to the terms of the headings and any relative section or chapter notes . . . ." And although not dispositive, the Explanatory Notes (ENs) to the Harmonized Commodity Description and Coding System represent the official interpretation of the tariff at the international level and facilitate classification under the HTSUS by offering guidance in understanding the scope of the headings and the GRIs.
As stated, the subject Multi-Touch Monitor is designed to connect directly to an ADP machine for the purpose of performing input and output functions in an ADP system. The ENs describe an ADP system as consisting of a central processing unit, an input unit, and an output unit and states that an input unit and output unit can be combined into one single unit within the system.
We would note that in order to be classified in heading 8471, the merchandise must meet the terms of a unit of an ADP system as specified in Legal Note 6 (C) of Chapter 84, HTSUS. In this regard, Note 6 (C) to Chapter 84 defines the term “data processing units” for purposes of heading 8471 as follows:
It is of a kind solely or principally used in an automatic data processing system;
It is connectable to the central processing unit either directly or through one or more other units; and
It is able to accept or deliver data in a form (codes or signals) that can be used by the system.
Further to meeting the conditions of Note 6 (C), the unit must not be excluded from any of the conditions provided for in Note 6 (D) and Note 6 (E) of Chapter 84, HTSUS. While monitors and projectors are excluded from classification in heading 8471, the subject Multi-Touch Monitor is not merely a display monitor, but instead meets the conditions set forth in the legal notes for ADP systems by comprising two of the three components within the system, namely the input and the output. As the touchscreen and the LED panel are permanently combined into a single unit, and the display unit is principally used within an ADP system for the purpose of performing a data processing function, the subject Multi-Touch Monitor will be classified in accordance with GRI-1 as a combined input output unit for ADP.
The applicable subheading for the 55" Multi-Touch Monitor for Computer Systems, Model 55MTM-2500B, will be 8471.60.1050, HTSUS, which provides for “Automatic data processing machines and units thereof; Input or output units, whether or not containing storage units in the same housing: Combined input/output units: Other.” The general 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 the World Wide Web at https://hts.usitc.gov/current.
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 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 protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division