CLA-2-84:S:N:N1:110 896417
Ms. Ann Marie Dowling
Seino America, Inc.
147-60 175th Street
Jamaica, N.Y. 11434
RE: The tariff classification of a PDT 3100 data terminal, keypads, and plastic housings from Taiwan and Singapore.
Dear Ms. Dowling:
In your letter dated March 29, 1994, you requested a tariff classification ruling.
The merchandise under consideration involves a PDT 3100 data terminal, the plastic/rubber keypad for this unit, and the plastic housing and frame for this unit. The PDT 3100 is a hand-held data collection computer that incorporates a 16-bit DOS industry standard operating system for application development. The PDT 3100 can be used by itself or with an integrated scan head option to maximize data collection productivity through laser scanning. This device has the ability to execute, without human intervention, a processing program which may modify the execution of the program by logical decision during the processing run. This device can be used as a data collection computer, but also for asset tracking, electronic ordering, and in-store retail applications. Noting Legal Note 5 (A) (a) to Chapter 84, this device would appear to meet the definition of a digital processing machine.
The silicone keypad for the PDT 3100 unit is specially designed for the hand-held computer and consists essentially of 35 plastic keys attached to a rubber frame. The back of the keypad incorporates small "carbon pills". Noting the Explanatory Notes for heading 8536, this keypad component for the PDT 3100 does not appear to fall under the definition of electrical apparatus for switching or protecting electrical circuits, or for making connections to or in electrical circuits.
The plastic molded parts for the PDT 3100 unit, such as the housing (top and bottom halves), cover, and frame, are specifically designed for the hand-held computer.
The applicable subheading for the PDT 3100 computer will be 8471.20.0090, Harmonized Tariff Schedule of the United States (HTS), which provides for digital automatic processing machines, containing in the same housing at least a central processing unit and an input and output unit, whether or not combined. The rate of duty will be 3.9 percent ad valorem.
THe applicable subheading for the keypad and plastic molded parts such as the housing, will be 8473.30.5000, HTS, which provides for other parts and accessories of the machines of heading 8471, not incorporating a cathode ray tube. 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