CLA-2-84:S:N:N1:103 803424
Mr. Michael O'Sullivan
Wall Shipping Co., Inc.
7513C Connelley Drive
Hanover, MD 21076
RE: The tariff classification of smart card production equipment from Germany
Dear Mr. O'Sullivan:
In your letter dated October 18, 1994 on behalf of Malco Plastics you
requested a tariff classification ruling.
You submitted literature describing equipment used to produce and test
smart cards. Smart cards are plastic credit cards which contain a memory chip
along with the usual magnetic strip, thus allowing various types of data to be
stored on the card. The production equipment which will be imported consists
of:
1. CMT6500/I testhandler - assists in testing memory chips, which are
mounted on a continuous tape, prior to their assembly to the plastic card.
The testhandler utilizes probes to connect the chips to external test
equipment, and then marks bad chips by means of a punch.
2. SCM5000 milling machine - automatically mills a cavity, into which a
chip will be placed, in the plastic card and then cleans the cavity by means
of a brush and air.
3. CML3500 glue tape laminating machine - deposits a hot melt glue
preform onto the back of the memory chip.
4. SCI8100 implanter machine - places and affixes a memory chip in the
cavity of the card by means of a hot press station.
You also inquired about two testers used in quality control for testing
a small quantity of completed cards:
5. SCF2300 flexion test system - physically tests a small number of
cards by continuously bending them.
6. SCT2400 torsion test system - physically tests a small number of
cards by twisting them to a 15 degree angle.
The applicable subheading for the functional unit formed by the
testhandler, milling machine, glue tape laminating machine, and implanter
machine, imported in a single shipment, will be 8477.80.0000, Harmonized
Tariff Schedule of the United States (HTS), which provides for other machinery
for working rubber or plastics or for the manufacture of products from these
materials, not specified or included elsewhere.... The rate of duty will be
3.9 percent ad valorem.
The applicable subheading for the flexion test system and the torsion
test system will be 9024.80.0000, HTS, which provides for other machines and
appliances for testing the hardness, strength, compressibility, elasticity or
other mechanical properties of materials. The rate of duty will be 4.8
percent ad valorem.
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