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NY I85428

September 10, 2002

CLA-2-84:RR:NC:1:103 I85428


TARIFF NO.: 8479.89.9897

Ms. Cheryl Wilson
Schenker, Inc.
835 South 192nd Street, Suite 900
Sea-Tac, WA 98148

RE: The tariff classification of a smart label assembly machine from Germany

Dear Ms. Wilson:

In your letter dated August 13, 2002 on behalf of Innovative Equipment you requested a tariff classification ruling.

Literature submitted with your inquiry describes the SL-L 100 and SL-L 400 machines used for the mass production of smart labels, also known as radio frequency identification (RFID) tags. Like bar codes, RFID tags are used to locate, track, and identify products. Such tags basically consist of an electronic transponder (an integrated circuit) and an antenna assembled to the surface of a substrate such as a paper or plastic label, tag, or ticket. The tag transmits electronically encoded data which is stored in the integrated circuit to a separate reader device via radio waves.

The SL-L 100 and SL-L 400 machines are composed of several unwinding stations, a transponder test station, assembly stations, a punching station and a rewinding unit. In operation, a reel of foil bearing the individual transponders is unwound and passed through the transponder test station. Simultaneously, a web of pre-printed labels is unwound and those transponders deemed acceptable are assembled to the labels by means of an application drum. An adhesive cover web is then unwound and applied to the web of transponder tags. Finally, a label shape punch cuts out the finished transponder label, and the trimmed material is removed and wound onto a reel. The SL-L 100 can produce from 8,000 to 10,000 transponder tags per hour. The SL-L 400 contains four separate tracks and is capable of producing 30,000 to 40,000 RFIDs per hour.

The applicable subheading for the SL-L 100 and SL-L 400 machines will be 8479.89.9897, Harmonized Tariff Schedule of the United States (HTS), which provides for machines and mechanical appliances having individual functions, not specified or included elsewhere (in chapter 84): other machines and mechanical appliances: other: other: other: other. The rate of duty will be 2.5 percent ad valorem.

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 Alan Horowitz at 646-733-3010.


Robert B. Swierupski

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