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HQ 956286




June 7, 1996

CLA-2 RR:TC:MM 956286 LTO

CATEGORY: CLASSIFICATION

TARIFF NO.: 8471.60.10; 8473.30.50

Mr. Laurence J. Lasoff
Mr. John B. Brew
Collier, Shannon, Rill & Scott
3050 K Street, N.W.
Suite 400
Washington, D.C. 20007

RE: Portable Data Collection Terminals; LDT 3805 Portable Data Collection Computer with Laser Scanner; plastic housings; HQ 956839

Dear Mr. Lasoff and Mr. Brew:

This is in response to a letter from Seino America, Inc., of March 29, 1994, requesting, on behalf of Symbol Technologies, Inc., the classification of the LDT 3805 Portable Data Collection Computer with Laser Scanner, as well as, the plastic housing for such a unit, under the Harmonized Tariff Schedule of the United States (HTSUS). In preparing this decision, we have also considered several supplemental submissions.

FACTS:

The LDT 3805 Portable Data Collection Computer with Laser Scanner (LDT 3805) is a microprocessor-based, lightweight, battery-operated, hand held data collection terminal. Data may be collected via a bar code scanning device or may be keyed into memory via an integrated keyboard. Information can be downloaded from the LDT 3805 to the host computer through an optically-coupled serial interface to a charging and communications module (CCM) or to a printer. The LDT 3805 can have up to 4.2 megabytes of RAM for data storage and multiple input and output capabilities for connection of printers, bar code readers and communication devices. - 2 -

A typical application for the LDT 3805 is a store-wide price change for the store's stock. To accomplish this task, the user programs the terminal to change the price of each product by, for example, ten percent. The user then scans the bar code of each product (or manually types the data into the terminal via the keypad). The terminal then retrieves the cost of the articles and calculates the new price. Then, using a portable printer unit, the system prints a new price tag bearing the ten percent change.

ISSUE:

Whether the LDT 3805 Integrated Laser Terminal is classifiable as an automatic data processing (ADP) machine or ADP input unit under heading 8471, HTSUS, or as an optical appliance or instrument under heading 9013, HTSUS.

LAW AND ANALYSIS:

The General Rules of Interpretation (GRI's) to the HTSUS govern the classification of goods in the tariff schedule. GRI 1 states, in pertinent part, that "for legal purposes, classification shall be determined according to the terms of the headings and any relative section or chapter notes . . . ."

Pursuant to section 625(c)(1), Tariff Act of 1930 (19 U.S.C. 1625(c)(1)), as amended by section 623 of Title VI (Customs Modernization) of the North American Free Trade Agreement Implementation Act (Pub. L. 103-182, 107 Stat. 2057), HQ 956839, which was issued to you, was published on April 17, 1996, in the Customs Bulletin, Volume 30, Number 16. In HQ 956839, we determined that the PDT 3100 portable data collection terminal was classifiable under subheading 8471.60.10, HTSUS, which provides for combined input/output units for automatic data processing (ADP) machines. While we cited GRI 3(b) (composite good/essential character) as the basis for the classification of the terminal, classification should have been made at the GRI 1 level, using note 3 to section XVI, HTSUS (multifunction machine/principal function). A "base assembly with speakers" for the PDT 3100 was classified as a part under subheading 8473.30.50, HTSUS, which provides for other parts and accessories for the machines of heading 8471, HTSUS.

The PDT 3100 portable data collection terminal, when imported with an optional laser scanner, is similar to the LDT 3805 portable data collection terminal, which includes an integrated bar code scanning device. For the reasons set forth
in HQ 956839, the LDT 3805 is also classifiable under subheading 8471.60.10, HTSUS (according to note 3 to section XVI), while plastic housings for the LDT 3805 are classifiable under subheading 8473.30.50, HTSUS.

HOLDING:

The LDT 3805 Portable Data Collection Computer with Laser Scanner is classifiable under subheading 8471.60.10, HTSUS, which provides for combined input/output units for automatic data processing machines. The corresponding rate of duty for articles of this subheading is 2.2% ad valorem.

The plastic housings for the LDT 3805 are classifiable under subheading 8473.30.50, HTSUS, which provides for other parts and accessories for the machines of heading 8471, HTSUS. The corresponding rate of duty for articles of this subheading is free.

Sincerely,

John Durant, Director

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