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HQ 967915

MARCH 22, 2006



TARIFF NO. 8472.90.10

Port Director
U.S. Customs and Border Protection
726 Exchange Street
Suite 400
Buffalo, NY 14210

RE: Internal Advice Concerning the Classification of the QuickJack Machine that is Used in Casinos of the Gaming Industry

Dear Port Director:

This is in response to your memorandum dated September 19, 2005, forwarding the internal advice request submitted by counsel on behalf of NRT Technology Corporation (NRT) concerning the classification of the QuickJack enhanced automatic teller machine (ATM) for use in the gaming industry under the Harmonized Tariff Schedule of the United States (HTSUS). Counsel provided a supplemental submission dated January 24, 2005.


The product at issue is known as the QuickJack Plus (QuickJack). It is a multi-function patron kiosk dedicated for use in the gaming industry by casinos. The QuickJack is an ATM to which certain hardware and software has been added in order to provide additional cash dispensing and related functions beyond those provided by a traditional ATM. To manufacture the QuickJack, NRT purchases a fully functional ATM machine the ProCash 1500 XE. The ProCash 1500 XE features all of the characteristics of a typical ATM, e.g., a numeric keypad (with encrypting and Braille labeling options), a card slot, a card reader, a display screen, cash dispensing cassettes, a security system, a receipt printer, a logo area, and a panel for card symbols. The ATM unit accounts for at least 65% of the total material cost of the manufactured QuickJack. By utilizing this machine and adding additional NRT developed software, the QuickJack is capable of communicating to a casino’s slot management system (SMS) in a manner similar to that of a change booth.

NRT manufactures the QuickJack by drilling holes in the side of the IBM ATM and attaching a side cabinet. Several cables are then routed from the ATM to the side cabinet that contains the hardware components, including a bill validator and a coin hopper. These items are joined to the ATM, so that the machine can perform some additional functions such as ticket cash redemption and bill breaking currency conversion etc. Additional software is also installed onto the ATM to support these systems. The ATM and the side cabinet are then mounted onto a common base. With the NRT enhanced machine, a casino attendant utilizes the intuitive ATM interface to enter key information, such as the slot ID and winning amounts. Instead of dispensing cash, the machines print bar-coded tickets that can be inserted into cashless slot machines on the casino floor and turned into credits that can be wagered. Counsel has informed us that the QuickJack Plus is a more advanced version of the QuickJack that NRT now sells to casinos. It is our understanding that the QuickJack is now not being sold. According to the promotional literature that was submitted, the QuickJack Plus offers casino patrons a user-friendly, intuitive environment in which to:

Redeem slot tickets for cash

Break bills

Redeem player points

Exchange currency

Withdraw cash on the ATM

The product was originally entered in subheading 8476.89.00, HTSUS, as: “Automatic goods-vending machines including money changing machines: machinesincluding money-changing machines; parts thereof: Other machines: Other.” The importer contends that the QuickJack is properly classified in subheading 8472.90.10, HTSUS, as an automatic teller machine.


Whether the QuickJack machine is classified in subheading 8472.90.10, HTSUS, as an automatic teller machine or in subheading 8472.90.90, HTSUS, as other currency and coin handling machines, or in subheading 8476.89.00, HTSUS, as other automatic goods-vending machines including money changing machines.


Classification under the HTSUS is made in accordance with the General Rules of Interpretation (GRIs). GRI 1 provides that the classification of goods shall be determined according to the terms of the headings of the tariff schedule and any relative section or chapter notes. In the event that the goods cannot be classified solely on the basis of GRI 1, and if the headings and legal notes do not otherwise require, the remaining GRIs may then be applied.

The HTSUS provisions under consideration are as follows:

8472 Other office machines (for example, hectograph or stencil duplicating machines, addressing machines, automatic banknote dispensers, coin-sorting machines, coin-counting or wrapping machines, penciling-sharpening machines, perforating or stapling machines):

8472.90 Other:

8472.90.10 Automatic teller machines.

8472.90.90 Other

8476 Automatic goods-vending machines (for example, postage stamp, cigarette, food or beverage machines), including money-changing machines; parts thereof:

Other machines:

8476.89.00 Other

The Harmonized Commodity Description and Coding System Explanatory Notes (EN’s) constitute the official interpretation of the Harmonized System. While not legally binding on the contracting parties, and therefore not dispositive, the EN’s provide a commentary on the scope of each heading of the Harmonized System and are thus useful in ascertaining the classification of merchandise under the Harmonized System. CBP believes the EN’s should always be consulted. See T.D. 8980, 54 Fed. Reg. 35127, 35128 (Aug. 23, 1989).

EN 84.76 states that:

This heading covers the various kinds of machines which supply some kind of merchandise when one or more coins, tokens or a magnetic card are put in a slot (other than those machines covered more specifically by other headings of the Nomenclature or excluded from the Chapter by a Chapter or Section Note).

The heading includes coin-operated machines for selling postage stamps, railway tickets, chocolate, sweets, ice cream, cigarettes, cigars, beverages (such as beer, wine, liqueurs, coffee or fruit juices), toilet products (including scent spraying machines), stockings, photographic films, newspapers, etc.; also machines on which name plates can be stamped out on a strip of metal.

The heading also covers money-changing machines.

Although when the QuickJack was entered, it was originally classified in heading 8476, HTSUS, as an automatic goods-vending machine, we find that the machine under consideration cannot be classified in heading 8476, HTSUS, because it is not primarily intended to supply merchandise when money is deposited in it. The QuickJack does perform several functions that are unique to a casino environment such as redeeming slot tickets for cash, breaking bills, redeeming player points, and exchanging currency. While some of these functions such as the bill breaking and the exchanging currency functions are more typical of the machines that are classified in heading 8476, HTSUS, we believe that these so-called “casino functions” are ancillary to the basic ATM functions that the QuickJack performs, which are the accessing of accounts and the conducting of financial transactions at a casino.

We now recognize that the QuickJack is most appropriately classified in heading 8472 HTSUS, as other office machines because it is basically a machine for handling the work of managing accounts at casinos that is not specifically covered by any other heading of the Nomenclature. See EN 84.72.

In classifying the QuickJack at the six-digit level, it is not contested that the QuickJack is properly classified in the other basket provision of subheading 8472.90, HTSUS. Consequently, this means the question that must be resolved is in which subheading under 8472.90 is the QuickJack classified. Since the issue arises at the eight-digit level, we begin our analysis using GRI 6. GRI 6 provides that for legal purposes, the classification of goods in the subheading of a heading shall be determined according to the terms of those subheadings and any related subheading notes, and mutatis mutandis, to the above rules, on the understanding that only subheadings at the same level are comparable. GRI 6 thus incorporates GRIs 1 through 5 in classifying goods at the subheading level. In addition, unless the context otherwise requires, the relative section and chapter notes also apply. Accordingly, the issue at hand is whether the QuickJack is classified in subheading 8472.90.10, HTSUS, as an automatic teller machine or in the basket provision of subheading 8472.90.90, HTSUS, as an other currency and coin handling machine.

EN 84.72 denotes that heading 8472, HTSUS, includes automated teller machines with which customers deposit, draw and transfer money and see the balances of their accounts without direct contact with bank personnel.

The web site www.Answers.com provides the following two definitions for the term automated teller machine:

An unattended electronic machine in a public place, connected to a data system and related equipment and activated by a bank customer to obtain cash withdrawals and other banking services. Also called automatic teller machine, cash machine; also called money machine.

A banking terminal that accepts deposits and dispenses cash. ATMs are activated by inserting a cash card or credit card that contains the user’s account number and PIN on a magnetic stripe. The ATM calls up the bank’s computers to verify the balance, dispenses cash and then transmits a complete transaction notice. The word “machine” in the term “ATM machine” is certainly redundant, but widely used.

In this instance, the QuickJack machines are manufactured from a pre-existing ATM. They incorporate features that are usually found on an ATM such as a numeric keypad, a card slot, a card reader, a display screen, cash dispensing cassettes, a security system, a receipt printer, a logo area, a panel for card symbols, and the appropriate operating system. In addition, the QuickJack is also able to perform several functions that are applicable in a casino environment that a typical ATM does not perform, such as redeeming slot tickets for cash, breaking bills, redeeming player points, and exchanging currency.

After consideration, we find that the QuickJack is primarily an ATM and should be classified as such. First, we note that once a QuickJack is connected to a banking network, an end user can use it for typical ATM services like balance inquiries, withdrawal of funds from checking, savings and credit accounts, as well as to transfer funds between such accounts. In fact, the importer’s counsel indicates that many casinos purchase a QuickJack primarily because of its ATM functionality. In addition, the QuickJack can function as an ATM for accessing internal accounts that are established with a casino. After the casino patrons set up a casino account, by means of a player card, the QuickJack can be used for these casino accounts similar to the way any other ATM can be used to make withdrawals, make deposits, and check balances.

Based on the information available, it appears that the principal purpose of the QuickJack is to allow casino patrons the capability to conduct monetary transactions electronically with either a financial institutions such as a bank or with the casino without the assistance of a teller. The importance of the ATM unit to the QuickJack is shown by how it is produced. The QuickJack is manufactured basically by adding some components and software to a pre-existing fully functional ATM unit. After the manufacturing process is completed, the QuickJack retains the ATM core processing functions. Furthermore, the ATM will continue to serve as the central processor for all the functions of the QuickJack. In other words, without the critical connectivity to the ATM, the added components of the QuickJack would be useless. In addition, we also note that the ATM accounts for at least 65 percent of the cost involved in the manufacturing the QuickJack.

While the QuickJack will perform some additional functions not found on a typical ATM, we also take note that according to the web site www.Answers.Com, some ATMs perform many functions which are not directly related to the management of one’s own bank account such as: paying routine bills, fees, and taxes (utilities, phone bills, social security, legal fees, taxes, etc.) loading monetary value into pre-paid cards (e.g. cell phones, tolls, multi purpose stored value cards, etc.) ticket purchases (train, concerts, etc.). Many ATMs in the United States also allow users to purchase stamps. Thus, we believe that the QuickJack’s additional functions for use at a casino should not disqualify it from being considered as an ATM.

Finally, the proposed alternative subheading for the QuickJack, subheading 8472.90.90, HTSUS is an other or basket provision. The "other," or "basket," provision of a subheading should be used only if there is no tariff category that more specifically covers the merchandise. See GRI 3(a) ("The heading which provides the most specific description shall be preferred to headings providing a more general description."). See also HQ 966621 dated February 18, 2004. Because the QuickJack fits the basic criteria of an Automatic Teller Machine, we conclude that it is most appropriately classified in subheading 8472.90.10, HTSUS, as an Automatic Teller Machine.


In accordance with GRIs 1 and 6, the QuickJack terminal for use in gambling casinos is classified in heading 8472, HTSUS. It is specifically provided for in subheading 8472.90.10; HTSUS, as: “Other office machines (for example, hectograph or stencil duplicating machines, addressing machines, automatic banknote dispensers, coin-sorting machines, coin counting or wrapping machines, penciling-sharpening machines, perforating or stapling machines): Automatic teller machines” at a general, column one rate which is duty free. Duty rates are provided for requester’s convenience and
are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on the World Wide Web at http://www.usitc.gov/tata/hts/.

You are directed to mail this decision to the internal advice applicant no later than 60 days from the date of this letter. On that date, the Office of Regulations and Rulings will make the decision available to CBP personnel, and to the public on the CBP Home Page on the World Wide Web at www.cbp.gov, by means of the Freedom of Information Act, and other means of public distribution. Sincerely,

Myles B. Harmon, Director Commercial and Trade Facilitation Division

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