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NY 882377

January 28, 1993

CLA-2-84:S:N:N1:110 882377


TARIFF NO.: 8473.29.0000

Mr. Richard Kaniss
Vertical Market Systems, Inc.
330 Melrose Bldg. 150 Suite "G"
Richardson, Texas 75080

RE: The tariff classification of point-of-sale keyboards from Taiwan.

Dear Mr. Kaniss:

In your letter dated December 17, 1992, you requested a tariff classification ruling.

The merchandise under consideration involves two models of keyboards, which are principally designed for use in point-of- sale transactions. The model Ai 8105T keyboard is about 2/3rd the size of a standard keyboard, and it weighs approximately 3- pounds. It has 12-numeric keys and 93 individual keys totalling 105 full motion user definable keys which permit the user to build a data entry system to suit his specific requirements. This keyboard has double and quad size keys, and removable key caps with plain or color key checks which can be utilized to perform specific functions. You can attach up to 4-RS 232-input devices, CCD, lasers, bar code slot scanners, check readers, and magnetic card readers into the Ai 8105T keyboard.

The model Ai 8120M keyboard comes standard with a flat 120 membrane keyboard which can be expanded to 480 keys by linking up to 4 Ai 8120s together. It weighs approximately 2-pounds. Like its' sister, the Ai 8105T, the Ai 8120M 120 keys are totally programmable permitting the user to suit his specific requirements. It has a flat membrane service which lends itself to the applications where moisture would come in contact with the unit. The Ai 8120M has 4-external RS 232-ports. An internal RS 232- port can be activated to accept credit card input through an optional magnetic card reader.

While these point-of-sale keyboards can be used with an ADP system, they are not "specially designed as part of an ADP system", and thus they do not meet the definition of a "unit" of an ADP machine. The model Ai 8105T and model Ai 8120M keyboards are principally designed for point-of- sale applications with cash registers in fast food places, restaurants, and bars.

The applicable subheading for the point-of-sale keyboards will be 8473.29.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for other parts and accessories suitable for use solely or principally with the machines of heading 8470 (cash registers and point-of-sale terminals). The rate of duty will be 3.9 percent ad valorem.

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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