CLA-2-83:OT:RR:NC:N4:414
Ms. Irish Fullerton
BeCode USA
500 Boulder Court
Suite B
Pleasanton, CA 94566
RE: The tariff classification of locks, keycards and certain tools from Germany
Dear Ms. Fullerton:
In your letter dated January 4, 2016 you requested a tariff classification ruling on BeCode keyless lock systems.
Item 7-1-0400 BeCode AIR/AIR+ locks are radio-controlled locking systems for furniture and lockers. The AIR version is installed in an existing cylinder lock and AIR+ has an integrated lock that fits into any standard lock cutout. To operate the lock, the transponder is held in front of the BeCode AIR/AIR+, and is turned 90 degrees clockwise to open the lock. To lock it again, the transponder is turned 90 degrees counter clockwise.
Item 7-1-2401 Key Cards are transponders that take the form of a keycard, a keyring or a wristband. The RFID cards operate on 13.56 Megahertz technology.
Item 7-1-0200 BeCode EVO/EVO+ are electronic locking systems for furniture and lockers. These locks work without keys, power cables or transponders. The EVO version is installed in an existing cylinder lock and EVO+ has an integrated cam lock that fits any standard lock cutout. To activate the lock, the numbers for the individual code are entered by rotating and pressing the knob.
Item 7-1-4007 are tools for the BeCode AIR/AIR+ and EVO/EVO+ locks. They are used to remove the front crown of the locks in order to change the battery.
Item 7-1-1400, 1404, 1407-Cams are 40 mm cams which are available in three versions. They are the smooth cam, the angle 4 mm cam and the angle 7 mm cam. These attach to the extender of the lock in order for it to latch behind a strike plate.
Item 7-1-0601 BeCode PAD locks are integrated lever locks with keyboard entry. Item 7-1-0820 BeCode mini-PAD locks are latch bolt locks with keyboard entry. The BeCode PAD and BeCode mini-PAD are locking systems for furniture and lockers, and require a four to six digit code in order to operate. There are no keys, power cables or transponders required.
The applicable subheading for Item 7-1-0400 BeCode AIR/AIR+ locks, Item 7-1-0200-BeCode EVO/EVO+, Item 7-1-0601 BeCode PAD and Item 7-1-0820 BeCode mini-PAD will be 8301.30.0090, HTSUS, which provides for Padlocks and locks (key, combination or electrically operated), of base metal: Locks of a kind used with furniture: Other. The rate of duty will be 5.7 percent ad valorem.
The applicable subheading for Item 7-1-1400, 1404, 1407-Cams will be 8301.60.0000, HTSUS, which provides for Padlocks and locks (key, combination or electrically operated), of base metal: keys and parts of any of the foregoing articles, of base metal: Parts. The rate of duty will be 2.8 percent ad valorem.
We are unable to issue a classification ruling on Item 7-1-2401 keycards and Item 7-1-4007 tools at this time. We require additional information in order to classify the keycards and the tools.
Regarding the keycards, do they contain one or more electronic integrated circuits? Are the keycards solid-state non-volatile storage devices? If so, do they contain a connecting socket, comprising in the same housing one or more flash memories in the form of integrated circuits mounted on a printed circuit board? Do they include a controller in the form of an integrated circuit or discrete passive components, such as capacitors and resistors?
Also, are the subject keycards a “smart card”? Do they have embedded in them one or more electronic integrated circuits (a microprocessor, random access memory (RAM) or read-only memory (ROM) in the form of chips? If so, do they contain contacts, a magnetic stripe or an embedded antenna? Do the keycards contain any other active or passive circuit elements? If so, what are they?
Are the subject keycards similar to proximity tags or RFID cards? If so, please fully explain how they are similar. Are the subject keycards some type of material that stores or transmits data? If so, what do they store and what do they transmit?
Regarding the tools, we have identified the tools as the Tensioner, the Removal Crown and the Disassembly Gripper. Please provide the material composition for each of these tools. Specifically explain how these tools are used in the assembly and/or disassembly of the locks. Are they operated in the hand, or are they used in conjunction with other tools? Do any of these tools become part of, or remain with, the locks after assembly?
On future requests for classification rulings, please limit the request to five (5) items of the same class or kind on each ruling request. If you decide to resubmit your request for a ruling on the keycards and the tools, please mail your request to Director, National Commodity Specialist Division, Regulations and Rulings, Office of International Trade, 1100 Raymond Boulevard, Newark, New Jersey 07102, attn: Binding Ruling Request.
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 Barbara Kiefer at [email protected].
Sincerely,
Deborah C. Marinucci
Acting Director
National Commodity Specialist Division