The tariff classification of a Transaction Terminal, PinPad, and a Cadam Device from Japan.

NY 874189 May 14, 1992 CLA-2-84:S:N:N1:110 874189 CATEGORY: Classification TARIFF NO.: 8470.50.0020; 8473.29.0000 Ms. Ruth Kleinstein Japan Freight Consolidators (CA) Inc. Cargo Building No. 75 Jamaica, New York 11430 RE: The tariff classification of a Transaction Terminal, Pin Pad, and a Cadam Device from Japan. Dear Ms. Kleinstein: In your letter dated April 30, 1992, on behalf of OKI America Inc., you requested a tariff classification ruling. The articles in question are the OTT 2000 Transaction Terminal, Pin Pad, and a Cadam Device which are used with this transaction terminal. The OTT 2000 Transaction Terminal incorporates a 16-bit microprocessor with 256 K bytes of memory capacity, a 24-character keyboard containing a TELCO 12-key pad, and a 12-key function pad, a magnetic stripe card reader, a 2- line, 20-character alphanumeric vacuum fluorescent display, an auto-dial modem, and three RS 232C ports. The OTT 2000 is a multi-functional transaction terminal capable of performing various financial services such as Electronic Draft Capture, Electronic Credit Authorization, and Check Guarantee. It can also read the smart card as well as a magnetic stripe card. The Pin Pad is a device that is used for entering the Personal Identification Number associated with the individuals debit (ATM) card. It operates with point-of-sale terminals such as the OTT 2000 Transaction Terminal, and is normally imported and sold with such terminals. This Pin Pad consists of a TELCO 12-key pad, a LCD, 16-character display, and it has a 12-feet spiral cable. When imported with the transaction terminal, we would consider Legal Note 4 to Section 16 of HTS to be applicable, and thus treated as a functional unit. The Cadam Device is a card which plugs into the card acceptor device of the OTT 2000 Transaction Terminal. Its function is to authenticate the functions of any applications operated on a card acceptor device such as the OTT 2000 Transaction Terminal, and information used by them are stored into it. The Cadam Device also serves as a communication controller, and as a memory manager by storing secret information, and the setting of any guards against information access. It is treated as a functional unit when imported with the transaction terminal. The applicable subheading for the OTT 2000 Transaction Terminal, Pin Pad, and Cadam Device will be 8470.50.0020, Harmonized Tariff Schedule of the United States (HTS), which provides for cash registers (point-of-sale terminals). The rate of duty will be free. This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177). A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction. Sincerely, Jean F. Maguire Area Director New York Seaport