RE: The tariff classification of point-of-sale terminals from Mexico

U.S. Department of Homeland Security U.S. Customs and Border Protection National Commodity Specialist Division One World Trade Center, Suite 51.201 New York, NY 10007 U.S. Customs and Border Protection N364143 August 26, 2026 CLA-2-84:OT:RR:NC:N4:462 CATEGORY: Classification TARIFF NO.: 8470.50.0020 Natalie Smith Toshiba Global Commerce Solutions, Inc. 3901 South Miami Boulevard Durham, NC 27703 RE: The tariff classification of point-of-sale terminals from Mexico Dear Ms. Smith: In your letter dated August 7, 2026, you requested a tariff classification ruling. Images and product information were provided in lieu of a sample. The products under consideration are described as the Toshiba TCx620, TCx810, and TCx820 All-In-One devices. These devices all contain a touchscreen display, Intel CPU, Random Access Memory (RAM), solid state drive (SSD) storage, Windows IoT or Android operating system, Ethernet/USB connectivity, RJ45 serial interface, SIM card slot option, and Wi-Fi capability. The products are imported as a single, complete, functional unit containing the principal computing components required to receive, store, process, and output data. All models can be connected to various peripheral devices (i.e., keyboards, mice, cash drawers, receipt printers, barcode scanner, magnetic stripe readers, NFC payment readers, card readers, or external payment terminals) using standard connection types such as USB, USB-C, or ethernet. The peripheral devices are not installed at the time of importation and are sold separately. The TCx820, TCx810, and TCx620 devices are not imported preloaded with any payment processing software. All models can be freely programmed by the customer to fit their specifications, including the installation of point-of-sale (POS) specific software or connecting POS peripherals. You state that all models, while primarily purchased for retail use, are also used for other purposes, such as inventory management, servers, and back-office support. In your request, you suggest that the correct classification for the subject devices is 8471.41.0150, Harmonized Tariff Schedule of the United States (HTSUS). We disagree. The requested heading of 8471, HTSUS, provides for Automatic Data Processing (ADP) Machines. In order for a device to be classified within this heading it must be freely programmable in accordance with the requirements of the user. In our view, the instant devices, even without the specified POS software, are dedicated machines that are primarily
used for POS functions. Any use beyond that does not appear to be commercially viable. As such, classification within heading 8471, HTSUS, is not applicable. The intended use for these devices as POS terminals is further supported by the technical specifications provided and the product pages on the Toshiba website. The applicable subheading for the Toshiba TCx620, TCx810, and TCx820 All-In-One devices will be 8470.50.0020, HTSUS, which provides for “Calculating machines… ticket-issuing machines and similar machines…cash registers: Cash registers: Point-of-sale terminals.” The general rate of duty will be Free. The 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/. This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the classification stated above, the merchandise covered by this ruling may also need to be reported with either the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions covering exceptions to such tariffs. 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 CFR 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 Sandra Walia at [email protected]. Sincerely, (for) James P. Forkan Director National Commodity Specialist Division