The tariff classification of the HP Z VR Backpack G1 Workstation from China

N288935 August 22, 2017 CLA-2-84:OT:RR:NC:N2:120 CATEGORY: Classification TARIFF NO.: 8471.50.0150 Jean-Claude Excoffier HP Inc. 150 Route du Nant d’Avril Meyrin, CH1217 Switzerland RE: The tariff classification of the HP Z VR Backpack G1 Workstation from China Dear Mr. Excoffier: In your letter dated August 4, 2017 you requested a tariff classification ruling. The merchandise under consideration is identified as the HP Z VR Backpack G1 Workstation, hereafter referred to as the G1 Workstation, which you describe as a fully functional personal computer (PC) that can be worn on the user’s back by mounting it to a specially fitted backpack. Based on the information provided, the G1 Workstation consists of a compact enclosure which is populated with the processor, memory, storage, video graphics adapter, wireless adapter, and multiple USB and audio/video connections. Further, you state that at the time of importation the G1 Workstation is imported as part of a set with the backpack, batteries, a battery charger, electrical cables, AC power adapters, and a docking station, all of which are packaged ready for retail sale. As discussed hereafter, it is the opinion of this office that the essential character of this set is imparted by the Workstation. In your request you suggest the VR PC is classifiable under subheading 8471.50, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Automatic Data Processing (ADP) machines. We would note that for the Workstation to be considered an ADP machine, it must satisfy the requirements set forth in Chapter 84 Note 5, HTSUS. Based on the technical specifications provided, the G1 Workstation is a fully functional PC that comes preloaded with the Windows Operating System and is equipped with hardware and software that would allow it to perform as such. The Workstation has no limitations as to the addition or removal of software applications of the user’s choosing, and in its imported form is fully capable of performing data processing functions. Therefore, we are of the opinion that the requirements of Note 5 are satisfied and the G1 Workstation is a fully functioning ADP machine as described in the nomenclature. With regard to the remaining contents of the set, we would note that the Backpack, which functions more as a harness, is specifically designed to attach the PC and does not contain compartments for general storage. The docking station is one that is also specifically designed to accommodate the G1 Workstation and is used to facilitate the use of the device in a desktop configuration whereby users have the ability to connect input and output devices such as a monitor and keyboard. And lastly, the batteries, cables, and power adapters are all devices normally used and sold alongside ADP machines. Thus, as all of the aforementioned items are packaged together for retail sale and are considered a set for tariff purposes, where each item is working in conjunction with and contributing to the operation of the workstation, this office finds that the G1 Workstation imparts the essential character of the set and is consequently classified accordingly. Lastly, we would note that you have not requested the individual tariff numbers for each item and only require the set to be classified. The applicable subheading for the HP Z VR Backpack G1 Workstation will be 8471.50.0150, HTSUS, which provides for “Automatic data processing machines and units thereof… Processing units other than those of subheading 8471.41 or 8471.49, whether or not containing in the same housing one or two of the following types of units: storage units, input units, output units: Other.” The 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 World Wide Web at https://hts.usitc.gov/current. 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