CBP Ruling N355774 — The tariff classification of a point of Sale (POS) solution from Taiwan

Tariff classification

Headings: 8473, 9903

Product description

are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. This ruling is being

CBP rationale

set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP.

Full text

N355774
December 1, 2025
CLA-2-85:OT:RR:NC:N2:208
CATEGORY: Classification
TARIFF NO.: 8473.29.0000; 9903.02.60
Marybeth Wangler McKinely International Corp 617 Loch Lane Coppell, TX 75019 RE: The tariff classification of a point of Sale (POS) solution from Taiwan Dear Ms. Wangler: In your letter dated November 5, 2025, on behalf of your client Cinemark USA, you requested a tariff classification ruling. The merchandise under consideration is the Flytech Point of Sale (POS) solution, model number POS335N3, which is to be used in theaters to purchase concessions and tickets. The subject POS335N3 does not process payments; rather, it sends payment requests over the network to a separate Verifone P400 payment device located at each station facing the customer to complete the payment. As per the information provided, the subject POS solution is not freely programmable and cannot be used to perform general-purpose computing tasks. Moreover, this Flytech POS has the dedicated function to be used by Cinemark as a part of the POS solution. In your original request, you suggested that this merchandise should be classified in subheading 8471.49.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "Automatic data processing machines and units thereof…: Other automatic data processing machines: Other, entered in the form of systems." However, based on the provided information, the Flytech Point of Sale (POS) solution, model number POS335N3, does not meet Chapter 84 Note 6 A (ii) or 6 (E). Therefore, it is precluded from classification under heading 8471, Harmonized Tariff Schedule of the United States (HTSUS). The applicable subheading for this POS solution, model number POS335N3 will be 8473.29.0000, HTSUS, which provides for “Parts and accessories…suitable for use solely or principally with machines of headings 8469 to 8472: Parts and accessories of the machines of heading 8470: Other.” The general rate of duty will be Free.

Effective April 5, 2025, Executive Orders implemented “Reciprocal Tariffs.” All imported merchandise must be reported with either the Chapter 99 provision under which the reciprocal tariff applies or one of the Chapter 99 provisions covering exceptions to the reciprocal tariffs. At this time, products of Taiwan will be subject to an additional ad valorem rate of duty of 20 percent. At the time of entry, you must report the Chapter 99 heading applicable to your product classification, i.e. 9903.02.60, in addition to subheading 8473.29.0000, HTSUS, listed above. The tariffs and additional duties cited above are current as of this ruling’s issuance. 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 at https://hts.usitc.gov/. The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection 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, please contact National Import Specialist Lisa Cariello at [email protected].
Sincerely,
(for) Deborah Marinucci Designated Official Performing the Duties of the Division Director National Commodity Specialist Division

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