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NY 868663

November 15, 1991

CLA-2-84:S:N:N1:110 868663


TARIFF NO.: 8471.92.1090

Mr. David A. Eisen
Siegel, Mandell & Davidson, P.C.
One Astor Plaza
1515 Broadway
New York, N.Y. 10036

RE: The tariff classification of an Avon Personal Order Entry Terminal from the Philippines.

Dear Mr. Eisen:

In your letter dated November 7, 1991, on behalf of Avon Products, Inc., you requested a tariff classification ruling.

The merchandise under consideration involves a personal order terminal that is described as the "Avon Poet". This device consists of a portable, hand-held electronic data collection unit that will be used by Avon representatives for inputting merchandise orders and transmitting such information to a central mainframe computer network for processing.

The unit measures approximately 6 inches in length and 4 inches in width, includes a keyboard, an LCD display, a CPU, and is incorporated within a rigid plastic case. The unit is designed to accept and store various input from the sales representative, such as merchandise orders, including style numbers, quantity, color, and sizes. After input, the device is connected to a telephone line (which is inserted into the telephone jack situated on the side), and the information is transmitted to the mainframe so the order can be processed.

Noting Legal Note 5 (B) to Chapter 84 of HTSUS, this device meets the definition of a "unit" of an automatic data processing system. Since this terminal unit combines both input and output functions for a data processing system, it would fall under the definition of a combined input/output unit for ADP systems.

The applicable subheading for the Avon Personal Order Entry Terminal will be 8471.92.1090, Harmonized Tariff Schedule of the United States (HTS), which provides for combined input/output units. The duty rate will be 3.7 percent ad valorem.

Articles classifiable under subheading 8471.92.1090, HTS, which are products of the Philippines, are entitled to duty free treatment under the Generalized System of Preferences (GSP) upon compliance with all applicable regulations.

This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177).

A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction.


Jean F. Maguire
Area Director

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