The tariff classification of a vehicle-mount computer from Canada

NY R03816 May 9, 2006 CLA-2-84:RR:NC:1:120 R03816 CATEGORY: Classification TARIFF NO.: 8471.41.0095, 8471.49.1095, 8471.49.2100 Ms. Christine de Vera Psion Teklogix Inc. 2100 Meadowvale Blvd. Mississauga, Ontario L5N 7J9, Canada RE: The tariff classification of a vehicle-mount computer from Canada Dear Ms. de Vera: In your letter dated April 26, 2006 you requested a tariff classification ruling. The merchandise under consideration is the Psion Teklogix 8255 and 8260 Vehicle-Mount Computers. Each model measures approximately 11.3 inches wide by 9 inches high. Model 8255 is 4 inches deep while model 8260 is 2.5 inches deep. The Psion 8255 and 8260 utilizes IBM DOS 7.0 as its standard operating system. This computer is designed for mounting onto a vehicle for use in rugged field applications primarily targeted towards an inventory control or warehousing environment. The computers are housed within a 16-gauge steel with baked enamel finish enclosure. Standard features for this computer include a 32-bit 486 DX 66 MHz Microprocessor, 8 MB of RAM and 4 MB of Flash memory. The keyboard is 55 keys and can be of ABC, Qwerty or Azerty format. The display on model 8255 is vacuum fluorescent (VFD) with an active area of 2 inches by 6.5 inches. The display on model 8260 has an active area of 6.2 inches by 8.3 inches and has the option of an LCD or electroluminescent display. However this display contains the memory and CPU and is not contained in the same housing as the keyboard. Features include dual type II PCMCIA expansion slots: one for ATA expansion card for mass data storage and the other for choice of radio support. Extensive radio support includes: IEEE 802.11b 2.4 GHz frequency hopping spread spectrum; 902 MHz spread spectrum and narrowband; Mobitex wide area. Two industrialized input/output ports are included. The peripherals supported are coded and nondecoded tethered scanners, printers and serial devices. The Psion 8255 and 8260 Vehicle-Mount Computers do not contain their own power supply and are designed to be mounted onto a vehicle where they will be connected to the vehicles electrical system for its power source. Therefore, it is not considered portable. The applicable subheading for the Psion 8255 Vehicle-Mount Computers will be 8471.41.0095, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "Automatic data processing machines and units thereof… Other digital automatic data processing machines: Comprising in the same housing at least a central processing unit and an input and output unit, whether or not combined: Other." The general rate of duty will be free. As per Section XVI, Chapter 84, Note 5 (B) automatic data processing machines may be in the form of systems consisting of a variable number of separate units. Subheading Note 1 to Chapter 84 defines the term "systems" as automatic data processing machines whose units satisfy conditions laid down in note 5 (B) to Chapter84 which comprises at least a central processing unit (server), one input unit (keyboard), and one output unit (video monitor). Classification for the Psion 8260 Vehicle-Mount Computers would thus fall under 8471.49. The applicable subheading for the Psion 8260 Vehicle-Mount Computers with display will be 8471.49.1095, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Automatic Data Processing machines and units thereof; Other digital automatic data processing machines: Other, entered in the form of systems: Digital processing units entered with the rest of a system…, Other. The rate of duty will be free. The applicable subheading for the Keyboard will be 8471.49.2100, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Automatic Data Processing machines and units thereof; not elsewhere specified or included: Other digital automatic data processing machines: Other, entered in the form of systems: Input or output units, entered with the rest of a system, whether or not containing storage units in the same housing: Other: Keyboards. 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 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 Denise Faingar at 646-733-3010. Sincerely, Robert B. Swierupski Director, National Commodity Specialist Division