CLA-2-84:OT:RR:NC:N2:220
Samir Varma
Thompson Hine LLP
1919 M Street NW
Washington, DC 20036
RE: The tariff classification of smart displays from Japan
Dear Mr. Varma:
In your letter dated September 13, 2018 you requested a tariff classification ruling on behalf of your client, Panasonic Avionics Corporation.
The merchandise under consideration is referred to as the Smart Monitor Display Unit (SDU), PN RD-FW8800-51, which is described as a 24” LCD display monitor with a resistive touch overlay that is installed into the back of passenger seats on an aircraft for the purpose of providing the end user with an interface to the automatic data processing (ADP) network. Based on the information provided, end users interact with the various applications stored on the networked server where a multitude of applications and media files are stored. The SDU is said to perform a number of basic functions such as web browsing, interaction with installed applications, playing games, and video/audio entertainment which are some of the examples provided in your request. We would note that the subject display unit does not contain a tuner or channel selector and is designed to directly interface with the server.
In your request you suggest the SDU is sufficiently described as a monitor capable of connecting directly to an ADP machine and is properly classified under 8528.52.0000, Harmonized Tariff Schedule of the United States, (HTSUS). However, the SDU is connected to the ADP system and provides end users with access and control to the various functions of that system through the display of information as well as the ability to manipulate data and applications on the network. Therefore, we disagree with the suggested classification as the SDU is more appropriately described as a combined input/output unit for ADP machines.
The applicable subheading for the Smart Monitor Display Unit, PN RD-FW8800-51, will be 8471.60.1050, HTSUS, which provides for “Automatic data processing machines and units thereof; Input or output units, whether or not containing storage units in the same housing: Combined input/output units: Other”. The general 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 https://hts.usitc.gov/current.
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 Karl Moosbrugger at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division