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HQ 950331

December 2, 1991

CLA-2 CO:R:C:M 950331 AJS


TARIFF NO.: 8471.92.10

Mr. Ray Carman
Director of Engineering
Data Control Systems, Inc.
2 Gourmet Lane, Suite F
Edison, NJ 08837

RE: Quantity Indicator Panel; Chapter 84, note 5(B); ENs 84.71 (A)(2); ENs 84.71(A)(3); heading 8531; ENs 85.31; H. Conf. Rep. No. 576.

Dear Mr. Carman:

Your letter of September 3, 1991, regarding the tariff classification of the PicRite Quantity Indicator Panel (QIP) has been forwarded to this office for reply.


The QIP is used with a Personal Computer (PC) and Bay Distribution Panel (BDP) to form a Paperless Order Picking System. The QIP is an electronic device which incorporates a light-emitting diode (LED) panel, passive and active components, two boards, switches, and a high-impact, non-conductive mounting. The QIP receives a four digit number indicating the number of pieces to be picked, and displays this information for the order picker. It also allows the picker to extinguish the display by activation of either a "short" switch or a "complete" switch which sends this information to the PC for recordation. The QIP is connected to the PC through the BDP.

The QIP is comprised of two printed circuit boards interconnected in a piggy-back fashion. The top board contains four seven segment LED displays and two pushbutton switches. The lower board contains the control logic circuitry. Four integrated circuits located on the lower board perform lighting, connection, and control functions.


Whether the QIP is properly classifiable within heading 8471, Harmonized Tariff Schedule of the United States (HTSUS), which provides for automatic data processing (ADP) machines and units thereof; or classifiable within 8531, HTSUS, which provides for "[e]lectric sound or visual signaling apparatus (for example, bells, sirens, indicator panels . . ."


Heading 8471, HTSUS, provides for ADP machines and units thereof. ADP machines may be in the form of systems consisting of a variable number of separately housed units. Chapter 84, note 5(B). A unit is to be regarded as being part of the complete system if it meets all of the following conditions:

(a) It is connectable to the central processing unit (CPU) either directly or through one or more other units; and

(b) It is specifically designed as part of such a system (it must, in particular, unless it is a power supply unit, be able to accept or deliver data in a form (code or signals) which can be used by the system). Chapter 85, note 5(B).

The subject QIP satisfies this description of a "unit". It is connected indirectly to a PC and specifically designed as part of a Paperless Order Picking System. Accordingly, the QIP satisfies the terms of heading 8471, HTSUS.

Subheading 8471.92.10, HTSUS, provides for combined input/output units. The Harmonized Commodity Description and Coding System Explanatory Notes (ENs) state that input units receive input data and convert it into signals which can be processed by an ADP machine. ENs 84.71 (A)(2), p. 1298 (1991). The QIP satisfies this description. It allows the picker to send data to the PC by use of either of two switches. An output unit converts the signals provided by the ADP machine into intelligible form (printed text, graphs, displays, etc.). ENs 84.71 (A)(3). The QIP also satisfies this description. It converts output data from a PC into a display. While the ENs are not dispositive, they provide a commentary on the scope of each heading and offer guidance for interpretation of the HTSUSA. H. Conf. Rep. No. 576, 100th Cong., 2d Sess., p. 549, reprinted in 1988 U.S. CODE CONG. & ADMIN. NEWS p. 1582. Consequently, we consider these notes instructive for determining that the QIP satisfies the terms of this subheading.

Heading 8531, HTSUS, provides for indicator panels. They are described as being devices used for calling personnel, indicating where a certain person or service is required, indicating whether a room is free or not. ENs 85.31, p. 1381 (1991). The subject QIP does not satisfy this description. It is not used merely for indication as described above. It is used in an ADP system for the input and output of data. Accordingly, the QIP does not satisfy the terms of heading 8531, HTSUS, and is not properly classifiable therein.


The PicRite QIP is classifiable within subheading 8471.92.10, HTSUS, which provides for combined input/output units currently dutiable at the General Column 1 rate of 3.7 percent ad valorem.


John Durant, Director
Commercial Rulings Division

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