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HQ 088225

January 31, 1991

CLA-2 CO:R:C:G 088225 JMH


TARIFF NO.: 8531.20.00

Mr. William C. Dart
PriceLink, Inc.
2344A Walsh Avenue
Santa Clara, CA 95051

RE: PriceLink display module to be used for LCD visual display of price information in grocery stores; Electronic Shelf Tag; visual signaling apparatus; indicator panel; parts and accessories of automatic data processing machines; Section XVI, Note 2(a); Additional U.S. Rule of Interpretation 1(c)

Dear Mr. Dart:

Your October 12, 1990 request for a classification ruling for the display module imported from Hong Kong has been referred to this office for a reply.


The articles in question are the PriceLink system 2000 visual display modules, also known as Electronic Shelf Tags. The modules are to be imported from Hong Kong for use in grocery stores. The Shelf Tags display item, unit and other price information about the various products on each shelf in the grocery store.

The Electronic Shelf Tags are at most two inches wide and four inches long. The Shelf Tag is mounted on an aluminum shelf rail that attaches permanently to the edge of a store shelf. A radio transceiver located generally in the center of the store receives pricing data from the main computer system and then transmits the data to nodes throughout the store. Nodes are the devices which receive and convert the radio signal. One possible configuration has a node attached to the underside of every shelf which connects to approximately six Tags, while another configuration has a node hard-wired to up to a thousand Tags located throughout the store.

Once the node receives the pricing data it then converts and distributes the data to the Tags mounted on each shelf. Each Tag has an electronic address which corresponds to one product's UPC code. The transmission of information is coded according to the UPC code. The nodes will receive the pricing information from the radio transceiver according to UPC codes for the particular products to which they are connected. The nodes then distribute the information to the Tag with the appropriate address.

The Tags are programmed with their electronic addresses, one product's UPC code, by the use of the optical port. The optical port, a small cell found on the front of each Tag, is sensitive to ambient light levels. Slow changes in lighting levels are normalized. However, if the light level changes rapidly (either light or dark) an action is taken. A normal light condition that is altered to dark indicates that a customer has placed his or her finger over the optical port and the information displayed on the Tag changes. A normal light condition that is altered to bright indicates that a special light pen is communicating with the Tag to program it.

The information received by the Tags is the same information received by the store's point of sale terminals at the check-out counters. Price changes which are programmed into the point of sale terminals by the store's computer system are also relayed to the Tags on each shelf by the radio transceiver. Thus, the customers will see the current pricing information for each product when roaming through the store's aisles.

The Electronic Shelf Tags consist of a liquid crystal display, two integrated circuits (a standard 4-bit 2 CMOS microprocessor and a CLASIC semicustom analog ASIC circuit) which are wirebonded to a printed circuit board, various opto and discrete passive components, a zebra interconnect, and various metal and plastic housing components. The shelf rails consists of an aluminum extrusion, a PVC insulation strip and four wire conductors. Once a Tag is in a rail the Tag makes electrical contact with a four-wire bus through four spring contacts on the Tag's back. The four wires in the bus are power, ground, data and clock. The radio transceiver is a custom designed 902 to 928 MHz spread spectrum digital packet radio.


What is the appropriate classification for the Electronic Shelf Tags, the Pricelink System 2000 Display Module?


The classification of merchandise under the HTSUSA is governed by the General Rules of Interpretation ("GRIs"). GRI 1, Harmonized Tariff Schedule of the United States Annotated ("HTSUSA"), states in part that "for legal purposes, classification shall be determined according to the terms of the headings and any relative section or chapter notes..."

The Electronic Shelf Tags act as illuminated numerical displays for grocery store products' price information. The Tags visually signal to customers certain data in numerical form. The terms of heading 8531, HTSUSA, describe "Electrical sound or visual signaling apparatus (for example, bells, sirens, indicator panels, burglar or fire alarms), other than those of heading 8512 or 8530; parts thereof..." (emphasis added). The Tags are number indicators. According to the Explanatory Notes to the HTSUSA, number indicators are considered visual signaling apparatus to be included in heading 8531. Harmonized Commodity Description and Coding System ("HCDCS"), Explanatory Note 85.31(D)(2), Vol. 4, p. 1382. The Explanatory Notes, although not dispositive, are to be looked to for the proper interpretation of the HTSUSA. 54 Fed. Reg. 35127, 35128 (August 23, 1989).

You believe that the Shelf Tags are properly classified under heading 8473, HTSUSA, as "Parts and accessories (other than covers, carrying cases and the like) suitable for use solely or principally with machines of headings 8469 to 8472..." However, Section XVI, Note 2(a), HTSUSA, states that "parts which are goods included in any of the headings of chapters 84 or 85...are in all cases to be classified in their respective headings..." Furthermore, Additional U.S. Rule of Interpretation 1(c), HTSUSA, requires that a specific provision prevails over a "parts and accessories" provision. Therefore, if a more specific provision describes the Tags, they are precluded from classification in heading 8473.

It is the opinion of this office that the Electronic Shelf Tags meet the terms of heading 8531, in that the Tags are a form of indicator panels or visual signaling apparatus. Since a specific provision describes the Tags the proper classification for the Electronic Shelf Tags is subheading 8531.20.00, HTSUSA, as "Electric sound or visual signaling apparatus...Indicator panels incorporating liquid crystal devices (LCD's) or light emitting diodes (LED'S)..."


The PriceLink Electronic Shelf Tags imported from Hong Kong are used to visually signal numerical pricing information to
customers about products in grocery stores. Visual signaling apparatus are classified, in accordance with GRI 1, in heading 8531. The proper classification for the Electronic Shelf Tags is subheading 8531.20.00, HTSUSA, as "Electric sound or visual signaling apparatus...Indicator panels incorporating liquid crystal devices (LCD's) or light emitting diodes (LED'S)..."


John Durant, Director
Commercial Rulings Division

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