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February 23, 1999

CLA-2-84:RR:NC:1:110 D88265


TARIFF NO.: 8471.90.0000

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

RE: The tariff classification of Electronic Key Card Entry Device Systems from Spain.

Dear Mr. Schau:

In your letter dated February 10, 1999, on behalf of Tesa Entry System Inc., you requested a tariff classification ruling.

The merchandise under consideration involves Electronic Card Key Encoder Units which are known as the models HT20, HT22, HT24, and CT30 card key encoder devices. These digital process or input/output units function are to digitally encode the surface of the key card, store the data in memory, and to recall plus display individual location access information.

The card key encoder units house a keyboard, a LCD display, a microprocessor, and has 512 RAM (storage). 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. This key card system is typical of the keyless card security commonly utilized by hotels for room entry service. The principal function of these key card entry devices appears to be for transcribing data onto data media in coded form. Headquarter’s Ruling 957416 and NY Letter D81084 were the subject of similar merchandise.

The applicable subheading for the models HT20, HT22, HT24 and CT30 Electronic Card Key Encoder Units 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. 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 212-637-7019.


Robert B. Swierupski

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