CLA-2-84:RR:NC:1: 110 L83076

Ms. Jill M. Ross
GeoLogistics Americas Inc.
6925 Engle Road
Middleburg Hts., OH 44130

RE: The tariff classification of reader/duplicator from Italy.

Dear Ms. Ross:

In your letter dated February 3, 2005, on behalf of your client Bianchi USA you requested a tariff classification ruling.

The merchandise under consideration is the Strattec™ “Transponder Cloning Tool.” This is an electronic device used to duplicate “Quick-Code” signals used in automotive lock technology, for transfer onto an additional key. The Transponder Cloning Tool Quick-Code key cloning machine can detect, read and duplicate (in an appropriate key blank) fixed code from several types of transponder keys. This transponder receives and transmit RF (radio frequency) signals through an antenna. This device is encased within a single units with a read/write key insertion slot, LCD (Liquid Crystal Display), control buttons, USB and RS232 Serial Port interface for linking to a computer allowing simple high speed data transfer.

The applicable subheading for the Transponder Cloning Tool will be 8471.90.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for “…machines for transcribing data onto data media in coded form and machines for processing such data, not elsewhere specified or included: Other.” The general rate of duty will be free.

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 Eileen S. Kaplan at 646-733-3016.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division