The tariff classification of a Clean Hands monitoring unit from India

N153736 April 8, 2011 CLA-2-84:OT:RR:NC:1:120 CATEGORY: Classification TARIFF NO.: 8471.60.1050 Mr. Frederick Striley Clean Hands Company 10248 Page Industrial Drive St. Louis, MO 63132 RE: The tariff classification of a Clean Hands monitoring unit from India Dear Mr. Striley: In your letter dated March 15, 2011 you requested a tariff classification ruling. The submitted sample is being returned to you as requested. The merchandise under consideration is a Clean Hands monitoring unit. The unit is used to document the use of an automatic soap dispenser by restaurant and food service employees. The imported monitoring unit is connected to an automatic soap dispenser via a wire connection. Its microprocessor detects a 5-volt analog signal from the activation circuit of the dispenser, which indicates the flow of soap. Once the signal is detected, the monitoring unit converts this analog signal into a digital signal and plays an audio beep to initiate the unit’s microphone to record the employee’s speech. The recorded audio is sent to the central processing unit of an ADP machine, and is processed by the speech recognition software installed on that machine. The ADP machine identifies the employee based on the voice recognition, and sends the employee’s name back to the monitoring unit for display on its LCD screen while the employee is still washing his or her hands. The hand-washing event with date and time are then recorded to the employee’s database in the ADP machine. The monitoring unit is connected to the ADP machine via a standard power over Ethernet cable, which provides power to the units, and enables the transfer of data. An input unit receives input data and converts them into signals which can be processed by the machine. An output unit converts the signals provided by the machine into an intelligible form (printed text, graphs, displays, etc.) or into coded data for further use (processing, control, etc.). These units are combined into one single unit. The unit is performing a data processing function and meets Note 5 C to Chapter 84, Harmonized Tariff Schedule of the United States (HTSUS). The applicable subheading for the Clean Hands monitoring unit will be 8471.60.1050, HTSUS, which provides for: Input or output units, whether or not containing storage units in the same housing: Combined input/output units: 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