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NY D81084

August 19, 1998

CLA-2-84:RR:NC:1:110 D81084


TARIFF NO.: 8471.90.0000; 8302.41.6045; 8302.41.9045

Mr. Craig M. Schau
Emery Customs Brokers
6940A Engle Road
Middleburg Heights, OH 44130

RE: The tariff classification of Electronic Key Card Entry Device System Components from Italy.

Dear Mr. Schau:

In your letter dated August 3, 1998, on behalf of Cisa Security Products, you requested a tariff classification ruling.

The merchandise under consideration involves components that are part of a security key card system that are typically used with keyless card security systems commonly found in hotels for room entry service.

The following components represent the imported portion of this system: Card Key Encoder unit; Hand-held Interrogator; Card Key reader; Aluminum and steel handle & facia; and Brass handle and facia plate.

The Card Key encoder unit is used to encode the surface of the card key, store the data, and recall and display individual location information. The unit houses a keyboard, an LCD display, microprocessor, and a minimum of 251k RAM that is upgradeable. It stores the processing program, is programmed by the user's requirements, and encrypts the key cards with particular data that is obtained by the software. The principal function of this device appears to be for transcribing data onto data media in coded form, and would thus fall under the Part 2 provision of heading 8471. Please note HQ ruling 957416 of 6/20/95 that involved similar merchandise.

The Hand-held Interrogator is a portable data recovery unit that is used to download individual entrance location information from the card readers attached to the entrance doors. It is battery operated and reads the encoded data record of key card swipes. The user simply connects the Interrogator to the card key reader on the door by a cable and transfers the electronic data in the form of digital information, to the Interrogator.

The Door handle lever and exterior facia covers come in two varieties: aluminum and brass. They consist of a door handle lever and casing cover that houses the hand-held interrogator. They do not contain the mechanical lock assembly.

The applicable subheading for the Card Key Encoder unit and the Hand-held Interrogator will be 8471.90.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for other machines for transcribing data onto data media in coded form and machines for processing such data, not elsewhere specified or included. The rate of duty will be free.

The applicable subheading for the aluminum and steel handle & facia will be 8302.41.6045, HTS, which provides for other articles of iron or steel, of aluminum or of zinc, suitable for interior or exterior doors. The rate of duty will be 4.3 percent ad valorem.

The applicable subheading for the brass handle and facia plate will be 8302.41.9045, HTS, which provides for other articles of base metal, suitable for interior or exterior doors.

Regarding the classification of the card key reader device, please provide a sample of this device, since we are unable to rule on this article for lack of a better description and what it specifically incorporates.

This ruling is being issued under the provisions of Part 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.


Robert B. Swierupski

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