The tariff classification of the Peregrine Wearable Interface, a sensor apparatus, and a pod assembly from various countries.

N075435 October 9, 2009 CLA-2-84:OT:RR:NC:1:120 CATEGORY: Classification TARIFF NO.: 8471.60.9050, 8473.30.5100 Mr. Dale W. Flint Iron Will Creations 5006 18th Street Lloydminster, Alberta T9V 1V4 Canada RE: The tariff classification of the Peregrine Wearable Interface, a sensor apparatus, and a pod assembly from various countries. Dear Mr. Flint: In your letter dated August 31, 2009 you requested a tariff classification ruling. The merchandise under consideration is the Peregrine Wearable Interface GX1. A sample was submitted with your ruling request and will be returned to you. The Peregrine Wearable Interface is a user interface device that, through human interaction, communicates through a USB (universal serial bus) connection with an automatic data processing (ADP) machine. It is comprised of a sensor apparatus and a pod assembly which are designed to function together. The sensor apparatus consists of a Lycra/polyester fabric glove which includes 3 “touchpoints” of stainless steel mesh cloth integrated into the fabric. Two of the touchpoints are mounted on the thumb, and the third on the palm. Stainless steel wires coiled into spring shapes are permanently attached to the glove and run along each finger, the thumb, and the palm. Seventeen “target areas” are marked on the glove along the stainless steel wires. The wires connect to a circuit board (pod slot) on the back of the glove, which features eight pin connections and a nickel-plated magnet. The pod assembly contains an 8-bit microprocessor, and measures 1.38 inches wide by 1.5 inches long by .38 inches thick. One side of the pod provides eight contact pins and a ferrous metal plate, and is designed to connect to the pod slot on the glove. Permanently attached to the pod assembly is a 4-foot USB cable. During use, the glove is connected via the pod assembly to the user’s computer, which provides both a data connection and power to the pod assembly. The pod assembly in turn sends current through the circuit board to the springs. When the glove is worn, the user moves his or her fingers and thumb to cause contact between one of the touchpoints and the spring formed wires, which are resistive dividers. When the wires are touched by or to the pads on the thumb or palm, a resistive circuit is formed, and the signals are routed through the springs and are conveyed to the circuit board. The microprocessor within the pod measures the touch voltage, and converts it into a character, e.g., a letter, number, or keyboard command. The pod sends this character to the attached computer through the USB connection. The computer, onto which has been installed specific driver software compatible only with freely programmable ADP machines, interprets the data as a standard keyboard input or character. The Peregrine Wearable Interface GX1, consisting of the sensor apparatus (glove) and pod assembly, is a functional unit which meets the requirements of Note 5(C) to Chapter 84, Harmonized Tariff Schedule of the United States (HTSUS). It is solely or principally used in an ADP system; it is connectable to the central processing unit either directly or through one or more other units; and it is able to accept or deliver data in a form which can be used by the system. Specifically, the Peregrine Wearable Interface receives input data (hand gestures) and converts them into signals which can be processed by the machine. Thus, the Peregrine is an input unit of an ADP machine. When imported separately, the pod assembly also meets the requirements of Note 5(C) to Chapter 84, HTSUS. It receives the hand gesture input data from the glove to which it is attached, and converts that data into signals which can be processed by the machine. When imported separately, the sensor apparatus is an integral component required for the Peregrine Wearable Interface to function, and is suitable for use solely or principally with machines of heading 8471, HTSUS. The applicable subheading for the Peregrine Wearable Interface GX1 will be 8471.60.9050, HTSUS, which provides for Automatic data processing machines and units thereof…: Input or output units, whether or not containing storage units in the same housing: Other: Other: Other. The rate of duty will be Free. The applicable subheading for the pod assembly when imported separately will be 8471.60.9050, HTSUS, which provides for Automatic data processing machines and units thereof…: Input or output units, whether or not containing storage units in the same housing: Other: Other: Other. The rate of duty will be Free. The applicable subheading for the sensor apparatus (glove) when imported separately will be 8473.30.5100, HTSUS, which provides for Parts and accessories (other than covers, carrying cases and the like) suitable for use solely or principally with machines of headings 8469 to 8472: Parts and accessories of the machines of heading 8471: Not incorporating a cathode ray tube: Other. The 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 Denise Faingar at (646) 733-3010. Sincerely, Robert B. Swierupski Director National Commodity Specialist Division