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NY I80141

April 12, 2002



TARIFF NO.: 8526.91.0040

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

RE: The tariff classification of a Global Positioning System from South Africa.

Dear Mr. Morgan:

In your letter dated March 28, 2002 you requested, on behalf of your client Fast Track Technology Inc., a tariff classification ruling.

You state that the GEOTAB is a global positioning system which is composed of a GPS engine, an electronic board to store GPS co-ordinates, a GPS antenna, a wiring harness to provide power for the control box, a touch housing to provide access to stored GPS information, and a 12 volt, 24 volt relay. The system is designed to allow trucking fleet management to keep track of their driver’s deliveries and also the efficiency of their work. The system functions by recording satellite information while the vehicle is operating. Then the information is downloaded on to a smart key, which the driver uses to operate the truck. The information on the key is then downloaded to a computer and interpreted by software.

The applicable subheading for the GEOTAB global positioning system will be 8526.91.0040 Harmonized Tariff Schedule of the United States (HTS), which provides for which provides for Radar apparatus, radio navigational aid apparatus and radio remote control apparatus: Other: Radio navigational aid apparatus Other. The rate of duty will be free.

Your inquiry does not provide enough information for us to give a classification ruling on the pre-recorded management software, touch keys and key readers. Your request for a classification ruling should include samples of these products, literature on these products, and a specific description of how these products function. With regard to the software, does it have an image, sound, data and interactivity component? When this information is available, you may wish to consider resubmission of your request. We are returning any related samples, exhibits, etc. If you decide to resubmit your request, please include all of the material that we have returned to you. 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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