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NY N024149

March 13, 2008



TARIFF NO.: 8537.10.9060

Ms. Sherie Cuddy
Mohawk Customs & Shipping (Rochester), LLC 52 Marway Circle, Suite 1
Rochester, NY 14624

RE: The tariff classification of a plastic electronic keypad from China.

Dear Ms. Cuddy:

In your letter dated February 28, 2008, you requested a tariff classification ruling on behalf of your client, John D. Brush and Company, dba Sentry Group.

The merchandise under consideration is two electronic keypad lock assemblies, item numbers 504267 and 504310. A sample of item number 504301 was submitted with your ruling request and will be returned to you.

The submitted sample is an assembly constructed entirely of plastic in the shape of a round disk measuring approximately 1 inch thick with a diameter of approximately 3¾ inches. The face of the housing features a liquid crystal display (LCD), 10 numbered push-buttons (0-9) and two additional push-buttons labeled “CLEAR” and “PROG ENTER.” The complete assembly consists of a plastic case housing and base, printed circuit board (PCB), silicone keypad, LCD assembly and bracket. The PCB is populated with active and passive components including integrated circuits (ICs), memory, momentary contact switches, four PCB connectors, and wire leads with a 9 Volt battery connector. Item number 504267 is virtually an identical assembly.

The electronic keypad lock assemblies will be incorporated into fireproof safes. The keypad provides a user the capability of programming a secure combination or code into memory for access to the safe’s contents. When the correct combination is reentered into the keypad, an electrical circuit is completed, activating the locking mechanism to open the safe.

The applicable subheading for the digital electronic keypad lock assembly, item numbers 504267 and 504310 will be 8537.10.9060, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Boards, panels, consolesand other bases, equipped with two or more apparatus of heading 8535 or 8536, for electric control or the distribution of electricity: For a voltage not exceeding 1,000 V: Other: Other: Programmable controllers.” The general rate of duty will be 2.7 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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