The tariff classification of the Distrib( system from the Netherlands

NY F83368 March 15, 2000 CLA-2-84:RR:NC:MM:110 F83368 CATEGORY: Classification TARIFF NO.: 8471.49.1035; 8471.49.2900; 8471.49.7000; 8524.99.4000 Mr. Luc Aalmans, President AmDutch Distribution Products, LLC 85 Reservoir Street Cambridge, Massachusetts 02138 RE: The tariff classification of the Distrib( system from the Netherlands Dear Mr. Aalmans: In your letter dated February 14, 2000 you requested a tariff classification ruling. The merchandise is described as the Distrib( system. Detailed information was provided on this system. Distrib( is a computer based sorting and distribution system for warehouses. It consists of software and hardware that reports and tracks the customer orders and distribution actions within a warehouse or sorting operation. It monitors orders, customer deliveries, product allocation, invoicing, loading speed, sorting speed, and related functions. It is an industrial computer based system used for product distribution, allocation, invoicing, etc. You also provided the following information in a telephone conference on March 1, 2000. Distrib( will be imported as a system. The software is on the hard drive of the industrial computer. The industrial computer has a built in monitor and keypad. Distrib( is networked to the company’s main computer and supplies information for invoicing, billing, etc. The system consists of the following: Software Industrial personal computer (with built in monitor and keypad) Five PC’s for a typical system Display units (LED type with three lines. The alphanumerical line is divided into two sections.) 80 displays for a typical system Rails (connect the LED displays into the system) 100 meters for a typical system Power supply box One power supply for a typical system Noting Subheading Notes 1 to Chapter 84 of the HTS, the Distrib( system meets the definition of a “system”, since it incorporates a processor unit, one input unit, and one output unit. Classification would thus fall under 8471.49 for this system. Since the Distrib( system is also imported as a system, the additional components (rails) would appear to qualify as a functional unit, noting Legal Note 4 to Section XVI of the HTS, since they all contribute to a clearly defined function. The preloaded software on the hard disk of this computer would be separately classifiable noting Legal Note 6 to Chapter 85 of the HTS, and HQ ruling 950675 of January 7, 1992. The applicable subheading for the industrial personal computers will be 8471.49.1035, Harmonized Tariff Schedule of the United States (HTS), which provides for digital processing units entered with the rest of a system, whether or not containing in the same housing one or two of the following types of unit: storage units, input units, output units. The rate of duty will be free. The applicable subheading for the display units will be 8471.49.2900, Harmonized Tariff Schedule of the United States (HTS), which provides for other display units (entered in the form of systems). The rate of duty will be free. The applicable subheading for the power supply will be 8471.49.7000, Harmonized Tariff Schedule of the United States (HTS), which provides for power supplies (entered in the form of systems). The rate of duty will be free. The applicable subheading for the software will be 8524.99.4000, Harmonized Tariff Schedule of the United States (HTS), which provides for other, other recorded media. The rate of duty will be free. The applicable subheading for the rails of the Distrib( system, noting Legal Note 4 to Section XVI of the HTS, will be 8471.49.1035, which provides for digital processing units. The rate of duty will be free. 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 Eileen S. Kaplan at 212-637-7019. Sincerely, Robert B. Swierupski Director, National Commodity Specialist Division Pre-transmitted 3/15/2000 10:49 AM