The tariff classification of an Image Generator System from the United States for export

N266254 July 28, 2015 CLA-2-85:OT:RR:NC:N1:112 CATEGORY: Classification TARIFF NO.: 8543.70 Matthew Brown Rockwell Collins 400 Collins Road NE Cedar Rapids, IA 52498 RE: The tariff classification of an Image Generator System from the United States for export Dear Mr. Brown: In your letter dated June 30, 2015 you requested a tariff classification ruling. The item under consideration is referred to as the EP-80 Image Generator System (IGS). The IGS is a flight simulation system component that you describe as a “computer based image generator which renders real time simulated imagery based on flight through a synthetic environment”. The IGS consists of the Real Time (RT) Computer, the Scene Processor (SP), the Scene Processor Interface (SPI), the External Sensor Effects Generation Hardware (EXG), and the Reconfigurable Video Processor (RVP). Each of these components are interconnected in a rack mounted cabinet and are configured in accordance with the specific needs of the user. The IGS is said to connect directly to simulator host system to create a real world virtual training environment for use in aircraft, helicopter, and ground vehicle training scenarios. Depending on the configuration of system components, the IGS produces realistic imagery in flight and ground simulation training. You suggested the appropriate heading of the IGS is 8471, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Automatic data processing machines and units thereof”. We disagree as the EP-80 IGS performs a specific function other than data processing. As such, it is not classifiable in heading 8471, HTSUS, as an ADP machine. The applicable subheading for the EP-80 IGS will be 8543.70, HTSUS, which provides for “Electrical machines and apparatus…: Other machines and apparatus”. 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 World Wide Web at http://www.usitc.gov/tata/hts/. 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, Gwenn Klein Kirschner Director National Commodity Specialist Division