CLA-2-84:S:N:N1:110 874189
Ms. Ruth Kleinstein
Japan Freight Consolidators (CA) Inc.
Cargo Building No. 75
Jamaica, New York 11430
RE: The tariff classification of a Transaction Terminal, Pin
Pad, and a Cadam Device from Japan.
Dear Ms. Kleinstein:
In your letter dated April 30, 1992, on behalf of OKI
America Inc., you requested a tariff classification ruling.
The articles in question are the OTT 2000 Transaction
Terminal, Pin Pad, and a Cadam Device which are used with this
transaction terminal. The OTT 2000 Transaction Terminal
incorporates a 16-bit microprocessor with 256 K bytes of memory
capacity, a 24-character keyboard containing a TELCO 12-key pad,
and a 12-key function pad, a magnetic stripe card reader, a 2-
line, 20-character alphanumeric vacuum fluorescent display, an
auto-dial modem, and three RS 232C ports. The OTT 2000 is a
multi-functional transaction terminal capable of performing
various financial services such as Electronic Draft Capture,
Electronic Credit Authorization, and Check Guarantee. It can
also read the smart card as well as a magnetic stripe card.
The Pin Pad is a device that is used for entering the
Personal Identification Number associated with the individuals
debit (ATM) card. It operates with point-of-sale terminals such
as the OTT 2000 Transaction Terminal, and is normally imported
and sold with such terminals. This Pin Pad consists of a TELCO
12-key pad, a LCD, 16-character display, and it has a 12-feet
spiral cable. When imported with the transaction terminal, we
would consider Legal Note 4 to Section 16 of HTS to be
applicable, and thus treated as a functional unit.
The Cadam Device is a card which plugs into the card
acceptor device of the OTT 2000 Transaction Terminal. Its
function is to authenticate the functions of any applications
operated on a card acceptor device such as the OTT 2000
Transaction Terminal, and information used by them are stored
into it. The Cadam Device also serves as a communication
controller, and as a memory manager by storing secret
information, and the setting of any guards against information
access. It is treated as a functional unit when imported with
the transaction terminal.
The applicable subheading for the OTT 2000 Transaction
Terminal, Pin Pad, and Cadam Device will be 8470.50.0020,
Harmonized Tariff Schedule of the United States (HTS), which
provides for cash registers (point-of-sale terminals). The rate
of duty will be free.
This ruling is being issued under the provisions of Section
177 of the Customs Regulations (19 C.F.R. 177).
A copy of this ruling letter should be attached to the entry
documents filed at the time this merchandise is imported. If the
documents have been filed without a copy, this ruling should be
brought to the attention of the Customs officer handling the
transaction.
Sincerely,
Jean F. Maguire
Area Director
New York Seaport