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NY N004214

December 29, 2006



TARIFF NO.: 8470.29.0000; 8470.50.0020; 8471.60.9090

Mr. Gary Overman
Cubic Transportation Systems
1308 South Washington St.
Tullahoma, TN 37388

RE: The tariff classification of an automated fare collection system and its components, the country of origin was not stipulated.

Dear Mr. Overman:

In your letter dated December 5, 2006 you requested a tariff classification ruling.

The merchandise under consideration is the Multi-Function Point-of-Sale 3100 (P/N 3400-10018), Driver Control Unit 5000 (P/N 5500-10004) and the Passenger Validator (P/N 5300-10004). You have stated that Cubic Transportation Systems equipment “provides various types of ticket issuing, ticket collecting and calculating equipment for the purchase of tickets, various methods of validation equipment and entry gates, for light rail systems and bus systems.”

From the information you provide, the Multi-Function Point-of-Sale 3100 is a complete Point-Of-Sale (POS) system designed for ticket office and customer service operations. This system consists of a standard personal computer (PC), keyboard and mouse, 15 inch flat panel touch screen atop a fairbox, printer and card reader. The Multi-Function Point-of-Sale 3100 is designed for a variety of POS and ticket issuing systems that may include contactless smart cards, magnetic tickets and paper proof-of-payment tickets. The Multi-Function Point-of-Sale 3100 terminal interfaces with a central system to perform other functions including adding value to smart cards, verifying card balances, hotlisting lost and stolen cards, querying transaction histories, resolving disputes, reversing transactions, issuing credits and running reports. The Multi-Function Point-of-Sale machine may be configured with various optional printers, card readers, credit/debit processors, PIN pad, lockable cash drawers, displays and cameras.

The Driver Control Unit 5000 is a small device measuring approximately 6 inches tall by 9 inches wide and is 3.6 inches deep. As imported, the standard configuration has a 300 MHz Central Processing Unit (CPU), 16 MB of Flash memory, 64 MB DRAM and 256 KB EEPROM BIOS within a housing that features a Liquid Crystal Display (LCD), 16 programmable soft keys, numeric keypad, and other display navigational buttons. The Driver Control Unit 5000 calculates and displays values of money and/or tickets that are processed. The Driver Control Unit provides operators with a single interface for all bus systems log-on and operation, system configuration management, collection and communications of fare transactions and execution of maintenance diagnostics. External connections are provided for connecting to various other Cubic’s devices such as card readers, printers, global positioning systems, cellular modems, computer-aided dispatch and automated vehicle announcement, monitoring and passenger counting units. When used in conjunction with the Passenger Validator, this device provides the functionality of a complete mobile ticketing machine.

The Passenger Validator is a card reader that processes contactless smart cards. When combined with the Driver Control Unit, they provide a complete mobile ticketing system.

The applicable subheading for the Driver Control Unit 5000 (P/N 5500-10004) will be 8470.29.0000, HTSUS, which provides for “Calculating machines and pocket-size data recording, reproducing and displaying machines with calculating functions: Other electronic calculating machines: Other.” The general rate of duty will be free.

The applicable subheading for the Multi-Function Point-of-Sale 3100 (P/N 3400-10018) will be 8470.50.0020, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Calculating machines and pocket-size data recording, reproducing and displaying machines with calculating functionsticket-issuing machines and similar machinescash registers: Cash registers: Point-of-sale terminals.” The general rate of duty will be free.

The applicable subheading for the Passenger Validator (P/N 5300-10004) will be 8471.60.9090, HTSUS, which provides for "Automatic data processing machines and units thereofInput or output units, whether or not containing storage units in the same housing: Other: Other: Other: Other: Other: Other." The general rate of duty will be free.

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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