CLA-2-84:OT:RR:NC:N1:120
Ms. Gail Harrison
Datacard Group
11111 Bren Road West
Minnetonka, MN 55343
RE: The tariff classification for the Datacard® CE870™ Card Personalization System
Dear Ms. Harrison:
In your letter dated September 10, 2012, you requested a tariff classification ruling.
The merchandise under consideration is the Datacard® CE870™ card personalization system. It is a desktop system that produces ready-to-use, instant financial payment cards for banks and other financial institutions to issue to their customers for immediate use.
The CE870™ system is a functional unit comprised of two modules connected to each other by cable and locking mechanisms. The encoding module is the top module of the CE870™, which encodes customer information onto the magnetic stripe and/or smart card chip of a pre-printed, plastic cardstock. It features an automatic card feed with a 100 card input hopper, and supports a wide range of different types of pre-printed, plastic card stock with its optional 6 card input hopper. The embossing module is the bottom module, which embosses pertinent information onto the card such as the cardholder’s name, account number, and expiration date of the card. It can indent and emboss up to 150 characters onto a plastic card.
The CE870™ system is connectable to and communicates with a host automatic data processing (ADP) machine by means of Ethernet and USB connections. The user configures the card output using Datacard® CardWizard™ issuance software installed on the ADP machine. The CE870™ system can also be driven by Microsoft® Windows driver, CPX protocol, Open Card protocol, and custom DPCL interface. The customer’s data file information is sent to the CE870™ system through the Ethernet and USB connections. The CE870™ system personalizes the card based on the information received from the ADP machine.
The CE870™ system meets the requirements of Note 5(C) of Chapter 84, Harmonized Tariff Schedule of the United States (HTSUS) as a unit solely or principally used in an ADP system. It is connectable to the central processing unit (CPU) directly or through one or more other units, and is able to accept or deliver data in a form (codes or signals) which can be used by the system.
The embossing and encoding modules sold and shipped together as a system meet the definition of a functional unit per Note 4 to Sectional XVI, HTSUS. Both modules contribute together to one clearly defined function of encoding. When imported separately, the Datacard® CE870’s™ encoding module (top module) accepts and converts data from the ADP machine into coded form. It imparts the essential character of encoding, and meets the requirements of an ADP unit as per Note 5 (C) to Chapter 84, HTSUS. When imported separately, the Datacard® CE870’s™ embosser (bottom module) imparts the essential character of embossing, which is to mold or carve in relief. It is designed and dedicated to function as part of the Datacard CE870 unit.
The applicable subheading for the Datacard® CE870™ Card Personalization System will be 8471.80.9000, HTSUS, which provides for "Automatic data processing machines and units thereof…: Other units of automatic data processing machines: Other: Other." The rate of duty will be Free.
When imported separately, the applicable subheading for the Encoder (top module) of the Datacard® CE870™ Card Personalization System will be 8471.80.9000, HTSUS, which provides for "Automatic data processing machines and units thereof…: Other units of automatic data processing machines: Other: Other." The rate of duty will be Free.
When imported separately, the applicable subheading for the Embosser (bottom module) of the Datacard® CE870™ Card Personalization System will be 8473.30.5100, HTSUS, which provides for "Parts and accessories (other than covers, carrying cases and the like) suitable for use solely or principally with machines of heading 8469 to 8472: . . . Parts and accessories of the machines of heading 8471: Not incorporating a cathode-ray tube: . . .Other." 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,
Thomas J. Russo
Director
National Commodity Specialist Division