CLA-2-91:RR:NC:MM:114 B89650

Ms. Teresa Wolven
Expeditors International of Washington, Inc.
601 North Nash Street
Los Angeles, CA 90245

RE: The tariff classification of a time-recorder from Hong Kong

Dear Ms. Wolven:

In your letter dated September 11, 1997, on behalf of HM Electronics, you requested a tariff classification ruling.

You state that the commercial trade name for the item submitted is "System 20A, Speed-of-Service Timer." The timer-recorder's dimensions are: 15.9 x 12 x 3.5 inches. By means of a vehicle detecting device (the detecting device is added to the system in the U.S.), the time-recorder alerts the employee by visual and audible cues, to meet target service times in a drive-thru business. The audible cue sounds an alert tone when the customer's wait exceeds the targeted service time. The visual cue is a count-up timer indicating time in minutes and seconds on a four digit, light-emitting diode display. The digits are 2.3 inches high. The timer records to its database (based on configuration settings) the time elapsed before a customer is greeted, total time spent at the menu board, time spent waiting in the queue, at the cashier window and at the service window. The time-recorder is programmed through its built-in keypad or personal computer interface. The database information can be printed on the built-in thermal printer. The applicable subheading for the time-recorder will be 9106.10.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for time of day recording apparatus for measuring, recording or otherwise indicating intervals of time, with clock or watch movement or with synchronous motor...time registers: time-recorders. The rate of duty will be 40 cents each plus 6.2 percent ad valorem plus 2.2 cents per jewel (as a solid-state electronic article, the "System 20A, Speed-of-Service Timer has no (0) antifriction jewels).

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 212-466-5685.

Sincerely,

Robert B. Swierupski
Chief, Metals & Machinery Branch
National Commodity
Specialist Division