The tariff classification of CAR Module components from Germany

NY 893372 January 7, 1994 CLA-2-84:S:N:N1:110 893372 CATEGORY: Classification TARIFF NO.: 8473.30.4000; 8471.99.3200 Mr. John S. Rode Rode & Qualey 295 Madison Avenue New York, N.Y. 10017 RE: The tariff classification of CAR Module components from Germany Dear Mr. Rode: In your letter dated December 17, 1993, on behalf of Unisys Corporation, you requested a tariff classification ruling. The merchandise under consideration involves component parts of a "CAR Module" (Courtesy Amount Reader) that is basically a unit of a data processing system used by financial institutions such as banks, for processing checks and other financial documents. Paper checks and other financial documents are commonly encoded with a line of characters which may be read optically or magnetically by a document processor as the documents are transported through that machine in the course of physical sorting. The CAR Module in its complete state, is connected by cable to a Document Processor and to a V series host computer, which controls the system as a whole, and to the storage and retrieval modules, work stations, and other equipment in the LAN. The CAR Module receives a portion of the digitized image created by an Imagecapture Module in the Document Processor from each check which passes through that document processor. The specific purpose for which the CAR Module is used is to determine the "courtesy amount" which appears on a paper document, such as a check, and present the amount so determined in digital electronic form suitable for use within the system in which the CAR Module is integrated. The principal components of a complete CAR Module normally includes the following: a chassis which includes a card-cage; a printed circuit backplane; an integrated power supply; a PC processor; a power distribution and control unit; three types of printed circuit board assemblies; and cables and connectors. The imported items will only include the chassis, backplane, power supply, and the three PCB assemblies. The other components will be added in the U.S. and assembled into a complete free-standing CAR Module unit. Noting Legal Note 5 (B) to Chapter 84 of the HTS, the complete CAR Module would meet the definition of a "unit" of an ADP system, under either part one or two of Heading 8471. In its imported condition, the components of the module would not appear to have the essential character of a complete or finished unit, noting GRI- 2(a). The component parts of the CAR Module would thus be classifiable as parts of the unit, or more specific provisions. The applicable subheading for the CAR Module chassis, backplane, and three PCB assemblies will be 8473.30.4000, Harmonized Tariff Schedule of the United States (HTS), which provides for parts and accessories of the machines of heading 8471 not incorporating a cathode ray tube. The rate of duty will be free. The applicable subheading for the incorporated power supply will be 8471.99.3200, HTS, which provides for power supplies suitable for physical incorporation into automatic data processing machines or units thereof. The rate of duty will be free. This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177). A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction. Sincerely, Jean F. Maguire Area Director New York Seaport