The tariff classification of MTO - Mobile Technical Office System and the AVL - Automatic Vehicle Location System from Hungary.

NY F88030 June 23, 2000 CLA-2-84:RR:NC:MM:110 F88030 CATEGORY: Classification TARIFF NO.: 8471.30.0000; 8524.39.4000; 8526.91.0040 Mary Kennette Customs & Transportation Manager Applied Innovations International Corp. 334 Rowntree Dairy Road Vaughan, Ontario L4L 8H2 RE: The tariff classification of MTO - Mobile Technical Office System and the AVL - Automatic Vehicle Location System from Hungary. Dear Ms. Kennette: In your letter dated May 10, 2000, on behalf of Applied Innovations Int'l Corp., you requested a tariff classification ruling. The merchandise under consideration is the MTO - Mobile Technical Office System and the AVL - Automatic Vehicle Location System. The first item is the MTO - Mobile Technical Office System. This item is a Portable digital automatic data processing machine, commonly referred to as a notebook/laptop computer. This computer has a central processing unit (CPU), flat display panel, keyboard and is equipped with a Global Positioning System OEM card and weights approximately 6 kilograms. It has a microprocessor with wireless data transmission interface to radio or satellite data transmission units. There are a number of options available such as a cell phone OEM card, Mobile Data Terminal and programmable keypad. This unit is designed to work as a portable office with access to standard word processing and spread sheet functions. It provides transmissions between other mobile units and/or a base computer. The applicable subheading for the MTO - Mobile Technical Office System will be 8471.30.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for "Automatic data processing machines and units thereof… Portable digital automatic data processing machines, weighing not more than 10 kg, consisting of at least a central processing unit, a keyboard, and a display." The rate of duty will be free. The second item is the AVL - Automatic Vehicle Location System. This is a two part system which consists of software that is installed on a desktop computer, and connects to a wireless communications network capable of sending and receiving digital data to and from mobile units. The software is on a CD, but is proprietary and must be installed by one of Applied Innovations programmers. It is then customized for each customer's application. The software application will be classified separately from the system itself as indicated in Legal Note 6 to chapter 85 HTS. The other part of this system is the GeoTrak AVL Hardware Unit. This unit is a Global Positioning System that is installed in a vehicle and consists of a GPS OEM card, HGI's microprocessor with wireless data transmission interface. Optional components consists of a cell phone OEM card and Mobile Data Terminal (MDT) consisting of graphics display capable of two way messaging. This AVL System is designed to track and monitor a variety of vehicles for fleet management. The applicable subheading for the AVL - Automatic Vehicle Location System Software in accordance with Legal Note 6 of Chapter 85 will be 8524.39.4000, Harmonized Tariff Schedule of the United States (HTS), which provides for "Records, tapes and other recorded media…: Discs for laser reading systems: Other: For reproducing representations of instructions, data, sound, and image, recorded in a machine readable binary form, and capable of being manipulated or providing interactivity to a user, by means of an automatic data processing machine; proprietary format recorded discs." The rate of duty will be free. The applicable subheading for the AVL - Automatic Vehicle Location System Hardware Unit will be 8526.91.0040, Harmonized Tariff Schedule of the United States (HTS), which provides for "Radar apparatus, radio navigational aid apparatus and radio remote control apparatus: Other: Radio navigational aid apparatus… Other." The rate of duty will be free. 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 Eileen S. Kaplan at 212-637-7019. Sincerely, Robert B. Swierupski Director, National Commodity Specialist Division