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NY 803424




November 10, 1994

CLA-2-84:S:N:N1:103 803424

CATEGORY: CLASSIFICATION

TARIFF NO.: 8477.80.0000; 9024.80.0000

Mr. Michael O'Sullivan
Wall Shipping Co., Inc.
7513C Connelley Drive
Hanover, MD 21076

RE: The tariff classification of smart card production equipment from Germany

Dear Mr. O'Sullivan:

In your letter dated October 18, 1994 on behalf of Malco Plastics you requested a tariff classification ruling.

You submitted literature describing equipment used to produce and test smart cards. Smart cards are plastic credit cards which contain a memory chip along with the usual magnetic strip, thus allowing various types of data to be stored on the card. The production equipment which will be imported consists of:

1. CMT6500/I testhandler - assists in testing memory chips, which are mounted on a continuous tape, prior to their assembly to the plastic card. The testhandler utilizes probes to connect the chips to external test equipment, and then marks bad chips by means of a punch.

2. SCM5000 milling machine - automatically mills a cavity, into which a chip will be placed, in the plastic card and then cleans the cavity by means of a brush and air.

3. CML3500 glue tape laminating machine - deposits a hot melt glue preform onto the back of the memory chip.

4. SCI8100 implanter machine - places and affixes a memory chip in the cavity of the card by means of a hot press station.

You also inquired about two testers used in quality control for testing a small quantity of completed cards:

5. SCF2300 flexion test system - physically tests a small number of cards by continuously bending them.

6. SCT2400 torsion test system - physically tests a small number of cards by twisting them to a 15 degree angle.

The applicable subheading for the functional unit formed by the testhandler, milling machine, glue tape laminating machine, and implanter machine, imported in a single shipment, will be 8477.80.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for other machinery for working rubber or plastics or for the manufacture of products from these materials, not specified or included elsewhere.... The rate of duty will be 3.9 percent ad valorem.

The applicable subheading for the flexion test system and the torsion test system will be 9024.80.0000, HTS, which provides for other machines and appliances for testing the hardness, strength, compressibility, elasticity or other mechanical properties of materials. The rate of duty will be 4.8 percent ad valorem.

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

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