The tariff classification of the “System 100” from an unspecified country of origin

N131678 November 24, 2010 CLA-2-85:OT:RR:NC:N1:112 CATEGORY: Classification TARIFF NO.: 8543.70.9650 Donna L. Hiltpold Stanley Black & Decker 480 Myrtle Street New Britain, CT 06053 RE: The tariff classification of the “System 100” from an unspecified country of origin Dear Ms. Hiltpod: In your letter dated November 5, 2010, you requested a tariff classification ruling. The item concerned is an RFID cart which is referred to as InnerSpace’s “System 100”. The “System 100” is a locking RFID cart/cabinet that incorporates radio frequency identification (RFID) technology, biometric access control electronics, an enrollment station, an RFID reader, a barcode scanner, RFID tags and utilizes a web-based information engine. This item is used to electronically secure, track and manage high cost clinical supplies. Access to the cart is controlled and monitored via a biometric security system. The biometric security system uses a fingerprint identification system to allow access to the contents of the cart. The device can store 188 fingerprint templates. It logs information pertaining to the individuals who access the cart and the time that the doors were opened and closed. The contents of the cabinet (high cost clinical supplies) are tracked using RFID technology. RFID tags are affixed to the outside package of clinical supplies; the item’s barcode is electronically linked to those tags. Radio frequency antennas embedded in the cart’s shelves are used along with the systems onboard computer to maintain constant communication with the RFID tags. This constant electronic monitoring operation allows for the tracking of the disposition, location and expiration dates of supplies. The top of the cart incorporates the power supply module and the Global Brain and Interconnect module (GBI). The access control/fingerprint module is attached to the front doors. The cart comes with ten RF-enabled shelves. The shelves connect and transmit data to the GBI (single board computer) via shielded CAT 5E cables. The RFID cart connects to the user’s computer network via an Ethernet port on the back of the device. The cart is fully integrated with the “spaceTRAX” supply management system (program). Each complete shelf assembly is comprised of the following: 1 antenna board; 1 antenna multiplexer board (AMB); 1 shelf housing (sheet metal); 1 shelf cover (ABS plastic). In your ruling request you suggest classifying the “System 100” cart in HTSUS 9403.10.0040, which provides for metal furniture of a kind used in offices. However, while the article does take the form of a cart, the “System 100” is a composite good and the essential character of this good appears to be imparted by the electronics held within. The presence of these electronics, and the important role they play in the use of the article would go beyond the definition of metal office furniture of subheading 9403.10. The applicable subheading for the “System 100” cart will be 8543.70.9650, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electrical machines and apparatus…: Other machines and apparatus: Other: Other: Other: Other”. The general rate of duty will be 2.6%. 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 Steven Pollichino at (646) 733-3008. Sincerely, Robert B. Swierupski Director National Commodity Specialist Division