CLA-2-84:OT:RR:NC:N1:120
Mr. Serge Desalvo
Russell A. Farrow (US) Inc.
8053 East Bloomington Freeway
Suite #400
Bloomington, MN 55420
RE: The tariff classification for the Horizon Evolution HD High-Volume Card Personalization System and the NBS-1500 Card Mailing System from Malaysia, Germany, and the U.K.
Dear Mr. Desalvo: In your letter dated September 23, 2014, you requested a tariff classification ruling on behalf of your client, Card Technology Corporation d/b/a NBS Technologies. The merchandise under consideration is the Horizon Evolution HD High-Volume Card Personalization System and the NBS-1500 Card Mailing System.
The Horizon Evolution HD High-Volume Card Personalization System (here-in-after “Horizon Evolution HD”) is a modular system that encodes alpha and numeric characters onto plastic cards with personalized information such as customer name, account numbers, expiration dates, and other specific information. It is comprised of a base unit and approximately eighteen separate card personalization elements (CPE’s) or “modules.” Any one or a combination of these separate modules are connectable to and communicates with a host automatic data processing (ADP) machine by means of Ethernet and USB connections.
The modules of the Horizon Evolution HD High-Volume Card Personalization System are as follows: The “Input CPE” includes two removable quick-change magazines, each with a 500 card capacity for faster and easier card handling; the “High Speed Dualco Magnetic Stripe Encoder CPE”; the “High Speed Smart Card CPE”; five “Printer CPE’s,” two of which print the top or bottom side of a card at a throughput speed of up to 1,500 cards per hour. The other three printers print color images at a throughput rate of between 500-800 cards per hour; the “Laminator CPE” enables a laminate material to be applied to the surface of a card to provide additional security and durability; the “High Speed Laser Engraving CPE” supplies durable, tamper resistant card personalization; the “Heavy Duty Embosser CPE” features the ability to dynamically adjust character height on a character by character basis; the “Tipper CPE” supports multiple tippers for faster and easier production; the “Card Labeler CPE” applies labels to the front of the card; the “Card Flipper CPE” correctly orients the cards for placement into downstream equipment; the “Card Stacker CPE” is configured to include up to three removable quick-change magazines, each with a 250 embossed card capacity and up to three stacker CPE’s; and the “Vision Inspection CPE” can fully verify all personalization without impacting the overall system throughput. The Horizon Evolution HD also includes an optional NBS-1500 Card Mailing System.
The NBS-1500 Card Mailing System is made up of two components, a Card Affixer unit and a Folder and Envelope unit. The Affixer unit reads cards by magnetic stripe or by contact or contactless smart card and then affixes the plastic card to specific paper forms. Additionally, the affixer validates that the plastic card is attached to the proper form for the recipient. The forms then pass through to the Folder and Envelope unit, which folds each form and inserts it into an envelope for mailing.
The above individual modules sold and shipped together as the Horizon Evolution HD system meet the definition of a functional unit per Note 4 to Section XVI, HTSUS. They are intended to contribute together to one clearly defined function of encoding. All of the other CPE’s are subsidiary in function to the “High Speed Dualco Magnetic Stripe Encoder” and the “High Speed Smart Card,” which give the Horizon Evolution HD its clearly defined function of encoding; These CPE’s perform the function of encoding customer information onto the magnetic stripe and/or smart card chip of a pre-printed, plastic cardstock.
The High Speed Dualco Magnetic Stripe Encoder module and the High Speed Smart Card module meet the requirements of an ADP unit per Note 5 (C) to Chapter 84, Harmonized Tariff Schedule of the United States (HTSUS). They are of the class or kind principally or solely used in an ADP system, connectable to the central processing unit (CPU) of an ADP machine directly or through one or more other units, and are able to accept or deliver data in a form (codes or signals) which can be used by the ADP system.
The applicable subheading for the Horizon Evolution HD High-Volume 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 NBS-1500 Card Mailing System will be 8472.30.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "Other office machines…Machines for sorting or folding mail or for inserting mail in envelopes or bands, machines for opening, closing or sealing mail and machines for affixing or canceling postage stamps." The rate of duty will be 1.8 percent ad valorem.
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: [email protected]. Sincerely,
Gwenn Klein Kirschner
Director
National Commodity Specialist Division