CLA-2-85:OT:RR:NC:N2:208
Marybeth Wangler
McKinely International Corp
617 Loch Lane
Coppell, TX 75019
RE: The tariff classification of a point of Sale (POS) solution from Taiwan
Dear Ms. Wangler:
In your letter dated November 5, 2025, on behalf of your client Cinemark USA, you requested a tariff
classification ruling.
The merchandise under consideration is the Flytech Point of Sale (POS) solution, model number POS335N3,
which is to be used in theaters to purchase concessions and tickets. The subject POS335N3 does not process
payments; rather, it sends payment requests over the network to a separate Verifone P400 payment device
located at each station facing the customer to complete the payment. As per the information provided, the
subject POS solution is not freely programmable and cannot be used to perform general-purpose computing
tasks. Moreover, this Flytech POS has the dedicated function to be used by Cinemark as a part of the POS
solution.
In your original request, you suggested that this merchandise should be classified in subheading
8471.49.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "Automatic
data processing machines and units thereof…: Other automatic data processing machines: Other, entered in
the form of systems." However, based on the provided information, the Flytech Point of Sale (POS) solution,
model number POS335N3, does not meet Chapter 84 Note 6 A (ii) or 6 (E). Therefore, it is precluded from
classification under heading 8471, Harmonized Tariff Schedule of the United States (HTSUS).
The applicable subheading for this POS solution, model number POS335N3 will be 8473.29.0000, HTSUS,
which provides for “Parts and accessories…suitable for use solely or principally with machines of headings
8469 to 8472: Parts and accessories of the machines of heading 8470: Other.” The general rate of duty will
be Free.
Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise
must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the
Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time, products of Taiwan will be
subject to an additional ad valorem rate of duty of 20 percent. At the time of entry, you must report the
Chapter 99 heading applicable to your product classification, i.e. 9903.02.60, in addition to subheading
8473.29.0000, HTSUS, listed above.
The tariffs and additional duties cited above are current as of this ruling’s issuance. 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 Lisa Cariello at [email protected].
Sincerely,
(for)
Deborah Marinucci
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division