CLA-2-84:RR:NC:1:110 C89003

Mr. Bill MacKay

Parking Paystations Int'l, Inc.

574 Erin Street

Winnipeg, Manitoba R3G 2V9

RE: The tariff classification of a parking paystation from Canada.

Dear Mr. MacKay:

In your letter dated June 10, 1998, you requested a tariff classification ruling.

The merchandise under consideration involves an automated unattended parking system which is known as an "Advanced Parking Control System" (APCS). This parking control system uses major components which include a Paystation, Entrance Controller, Exit Controller, Site Server, and Administrator.

The Paystation is a computerized payment terminal. It will accept a parking ticket and display the parking fee. It will then accept coins, bills or credit cards as payment, and will dispense the necessary change in coins and bills. It can also print a receipt if the customer wishes. The Paystation is operated by an industrial computer which is a single board computer with a diskette drive, and an "ArcNet" network card. The hardware devices are connected to the computer through a proprietary circuit board.

The Entrance Controller dispenses proprietary barcoded parking tickets. It also controls a standard electro-mechanical parking gate. The parking gate can be furnished to the customer if they do not have a parking gate or if a compatible parking gate is needed to function with the APCS. The Entrance Controller is also operated by an industrial computer as previously noted.

The Exit Controller resembles the Entrance controller but accepts tickets instead of dispensing them. It also controls a standard electro-mechanical parking gate. The Exit Controller also functions with an industrial computer as previously noted.

The Site Server controls an APCS network. It acts as a central data storage unit for the Paystations, Entrance Controllers and Exit Controllers. It also calculates parking fees. The Server consists of an industrial computer containing a single-board computer, a hard drive, a modem, a VGA display adaptor, and an ArcNet network card. The device is normally incorporated in the housing of the Paystation cabinet.

The Administrator allows the parking lot manager to set fee schedules, maintain the contract parking card database, generate activity reports, monitor the lot, and test the various devices. The Administrator consists of a standard desktop PC which operates on OS/2 Warp. The hardware includes a system unit, monitor, keyboard and mouse. The Administrator can connect to an APCS network through the telephone system by using a modem, or it can be connected to an APCS network by an ArcNet network card.

A single industrial PC may be used to control up to three Entrances or Exits, but only one Paystation. If it is used to control a Paystation, the industrial PC is mounted inside the Paystation cabinet. If it is used to control one or more entrances or exits, the industrial PC is mounted on the outside of one of the controller cabinets. All of the above PC's are connected through RG-62/U Coaxial Cable to ArcNet Hubs to form the APCS ArcNet system.

This APCS network appears to meet the definition of Section XVI, Legal Note 4 of the HTS. This parking system consists of a combination of machines,( whether separate or interconnected by electric cable or other devices), which contribute together to the clearly defined function of collecting parking fees, much like a cash register. Please note also Headquarters Ruling 087975 of January 23, 1991, for such or similar merchandise.

The applicable subheading for the Advanced Parking Control System (APCS) consisting of a Paystation, Entrance Controller, Parking Gate (if included), Exit Controller, Site Server, and Administrator will be 8470.50.0020, Harmonized Tariff Schedule of the United States (HTS), which provides for cash registers (point-of-sale terminals). The rate of duty will be free.

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 Art Brodbeck at 212-466-5490.

Sincerely,

Robert B. Swierupski

Director,

National Commodity

Specialist Division