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NY G82748

October 18, 2000

CLA-2-90:RR:NC:MM:114 G82748


TARIFF NOS.: 9106.10.0000; 9524.31.0070

Mr. James F. Morgan
883-D Airport Park Road
Glen Burnie, MD 21061

RE: The tariff classification of time recording apparatus and CD- ROM software from Germany

Dear Mr. Morgan:

In your letter dated September 15, 2000, on behalf of Isgus Incorporated, you requested a tariff classification ruling.

The Perfect 2000 is an electronic time recording device which operates off electric current. It is used for recording time and attendance on a monthly, weekly, bi-weekly or 5-weekly basis through the use of magnetic cards. The Perfect 2000 contains an analog quartz clock and has a power reserve provided by a lithium battery back-up device. It features automatic summer/winter time changes and a calendar that automatically corrects the date as needed at the end of the month.

The Terminal for Time Recording, Model 1000, contains a 16-digit alphanumeric LCD display with backlight. You indicate in your letter that the Model 1000 displays time on its LCD display. The Model 1000 has a magnetic card reader that an employee uses each time they arrive at or leave the facility. The employee swipes the magnetic card in the unit, which records the date and time into its database.

The Zeus Compact CD-ROM is a software program for a personal computer. It contains data in that it provides predefined reports such as holiday reports, vacation reports, absence reports, etc. The Zeus Compact CD-ROM is dedicated to work only with the Zeus Terminal (the Terminal for Time Recording, Model 1000). The data collected from the Model 1000, via connection to a personal computer and the use of the Zeus Compact CD-ROM software package, can be printed-out in a hard-copy format using a printer connected to a personal computer. It will report data such as the amount of time an employee is at work or away from work. It will report sick leave or vacation time taken and how much of either remains.

The applicable subheading for the Perfect 2000 and the Terminal for Time Recording, Model 1000 will be 9106.10.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for time registers; time recorders. The rate of duty will be 36 cents each plus 5.6 percent ad valorem plus 2 cents on each jewel.

The applicable subheading for the Zeus Compact CD-ROM will be 8524.31.0070, Harmonized Tariff Schedule of the United States (HTS), which provides for records, tapes and other recorded media for sound or other similarly recorded phenomena, for reproducing phenomena other than sound or image, other. 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 Barbara Kiefer at 212-637-7058.


Robert B. Swierupski

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