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NY N002911

November 22, 2006



TARIFF NO.: 8473.40.8500

Mr. Brian E. Johnson
Keytronic Corporation
4424 N. Sullivan Rd.
Spokane, WA 99216

RE: The tariff classification of an ATM security module from Mexico.

Dear Mr. Johnson:

In your letter dated November 11, 2006, you requested a tariff classification ruling.

The merchandise under consideration is the Triton Security Module. The security module is specifically designed for automated teller machines (ATM). This module consists of a molded plastic housing measuring approximately 2½ inches wide by 6 inches high with mounting ears and several Light Emitting Diodes (LED). Within this housing is a printed circuit board with active and passive components, integrated circuits (IC) and connectors. The security module is installed inside an ATM and connects the input or control panel to the cash-dispensing module. The function of the security module is to receive coded information from the ATM input module, which would be entered by a user by inserting a bankcard and entering a pin code, determine whether the code is correct before signaling the cash-dispenser to dispense any currency. If the code is incorrect, the security module ensures that the cash-dispenser module does not release any currency.

Articles that are integral, constituent components of another article, necessary to the completion of that article, and which satisfy a specific and integral need in the operation of that article qualify as parts for tariff purposes. Noting Legal Note 2(b) to Section XVI of the Harmonized Tariff Schedule of the United States (HTSUS), the security modules are designed and principally used with machines of heading 8472, HTSUS.

The applicable subheading for the Triton Security Module will be 8473.40.8500, HTSUS, which provides for “Parts and accessoriessuitable for use solely or principally with machines of headings 8469 to 8472: Parts and accessories of the machines of heading 8472: Other.” The general rate of duty will be 1.9 percent ad valorem.

Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.

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 Thomas Campanelli at 646-733-3016.


Robert B. Swierupski

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