The tariff classification of the HP t730 Thin Client from an undisclosed country

N295315 April 18, 2018 CLA-2-84:OT:RR:NC:N2:220 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 t730 Thin Client from an undisclosed country Dear Mr. Excoffier: In your letter dated March 20, 2018 you requested a tariff classification ruling. The merchandise under consideration is identified as the HP t730 Thin Client, which is described as a freely programmable computing device capable of running multiple operating systems, where users have the ability to install, store, and execute applications of their choosing. The HP t730 Thin Client incorporates an AMD processor and video graphics card, 16 GB of system memory, 128 GB storage, network communication functions, audio/display outputs, and comes with a USB mouse and keyboard. You state that the HP t730 Thin Client stores and runs programs and applications with associated data, such as Microsoft software applications, without needing to be connected to a server or to the Internet and functions similar to any standard personal computer (PC). In your request you suggest the HP t730 Thin Client 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 goods to be considered an ADP machine, it must satisfy all the requirements set forth in Chapter 84 Note 5 (A), HTSUS, which requies the machine is capable of: Storing the processing program or programs and at least the data immediately necessary for the execution of the program; Being freely programmed in accordance with the requirements of the user; Performing arithmetical computations specified by the user; and Executing, without human intervention, a processing program which requires them to modify their execution, by logical decision during the processing run. Based on the technical specifications provided, the HP t730 Thin Client is a fully functional PC that works within the various operating systems the user chooses to install 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 system administrator’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 (A) are satisfied and the HP t730 Thin Client is a fully functioning ADP machine as described in the nomenclature. The applicable subheading for the HP t730 Thin Client 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 unit: storage units, input units, output units: Other.” The general 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