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NY A80168

February 13, 1996

CLA-2-84:RR:NC:MA:110 A80168


TARIFF NO.: 8473.29.0000

Mr. Russ Hamblin
Fritz Companies Inc.
4141 East Raymond Street
Phoenix, AZ 85040

RE: The tariff classification of circuit board assemblies for transaction terminals from Australia and Japan.

Dear Mr. Hamblin:

In your letter dated February 2, 1996, on behalf of Hypercom Inc., you requested a tariff classification ruling.

The merchandise under consideration involves circuit board assemblies that are for Point-of-Sale transaction terminal models T7 and the PIN pad terminals model S series.

The T7 transaction terminals contain two circuit boards, one being the main board and the other is used as a keyboard. The pin pad boards are a one unit assembly. The T7 terminal incorporates a 35 key keyboard for check, debit, void, refund, off-line adjust, card verify and balance inquiry, as well as all of the normal management and control functions for reports, batch reviews, find transactions, reprint last or any receipt, and totals. It also incorporates a 2 x 20 back-lit LCD display, and a full track swipe card reader. This device can make a record of a transaction, and the information can be input automatically or manually. It also prints a charge receipt for the customer. This device also incorporates a modem, and is on-line with the credit card company/bank computer.

The Pin pad models (S7) are imported, shipped, and sold separately. In most retail applications, as per the inquirer, the T7 terminals are operated without the S7 pin pads, although they could be used in such an application. They are normally interfaced with electronic cash registers. The function of the pin pad is to give the customer account balances, by use of the PIN associated with the customers debit card.

Noting in part HQ ruling letters 086121 and 086537, these T7 transaction terminals would meet the definition of a cash register (point-of-sale terminal), since this heading covers registers working in conjunction, on-line or off-line, with an automatic data processing machine. Explanatory Note 84.70 (C), HCDCS, Vol. 3. p. 1295. The pin pad, since it is an accessory used with transaction terminals and ECR's, would be considered to fall under the definition of an "accessory" for the machines covered under heading 8470. Since only the circuit board assemblies are being imported for these two devices, and are apparently principally used with the transaction terminals and pin pads, classification as a part, noting Legal Note 2 (b) to Section 16, would be appropriate.

The applicable subheading for the printed circuit assemblies will be 8473.29.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for other parts and accessories of the machines of heading 8470. The rate of duty will be 3.1 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 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.


Roger J. Silvestri

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