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NY H88678

March 8, 2002

CLA-2-85:RR:NC:1:108 H88678


TARIFF NO.: 8525.20.9080

Mr. Stephen W. Marlow
Tower Group International, Inc.
205 West Services Road
Champlain, NY 12919

RE: The tariff classification of a mobile data terminal from Canada.

Dear Mr. Marlow:

In your letter dated February 14, 2002, on behalf of your client Aimtronics Corporation, you requested a tariff classification ruling.

The item in question is denoted as the MT 2000 Mobile Terminal (sample attached). The mobile terminal is a compact, portable device that consists of a single sealed mechanical enclosure with an integral antenna subsystem and a transceiver for communicating with mobile satellites. It does include a GPS location subsystem, an RS-232 I/O port, four digital I/O ports, two analog inputs, a power input, and a sensor power output.

The device is designed to transmit and receive short data messages using geostationary satellite frequencies. It can also be mounted on either fixed or mobile assets. It serves as a major component of the Global Wave satellite messaging service. It provides a two way wireless communication over a wide geographic area. It can monitor external sensors, send and receive data and obtain GPS location information. It can be used on fixed assets such as trucks, freight cars or pipelines as well as serve as mobile messaging terminal.

Very similar items were the subject of HQ Rulings 085404 and 087984. Both rulings held that mobile radio data terminals were composite machines whose principal function was that of radiotelegraphy. The items enabled field personnel to transmit and receive information from a remote position to a base office via a radio link.

Based upon this information it is the opinion of this office that the principal function of the MT 2000 Mobile Terminal is that of wireless data transmission (radiotelegraphy).

The applicable subheading for the MT 2000 Mobile Terminal will be 8525.20.9080, Harmonized Tariff Schedule of the United States (HTS), which provides for Transmission apparatus for radiotelephony, radiotelegraphy, radiobroadcasting or television, whether or not incorporating reception apparatus or sound recording or reproducing apparatus; television cameras; still image video cameras or other video camera recorders; digital cameras: Transmission apparatus incorporating reception apparatus: Other 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 Michael Contino at 646-733-3014.


Robert B. Swierupski

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