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NY D82145




September 10, 1998

CLA-2-84:RR:NC:1:110 D82145

CATEGORY: CLASSIFICATION

TARIFF NO.: 8471.90.0000

Mr. Craig Schau
Emery Customs Brokers
6940A Engle Road
Middleburg Heights, Ohio 44130

RE: The tariff classification of a card key reader device from Italy.

Dear Mr. Schau:

In your letter dated August 27, 1998, on behalf of Cisa Security Products, you requested a tariff classification ruling.

The merchandise under consideration involves an electronic card/key magnetic media entry unit which is known as the "Verifier". This card key reader entry device measures approximately 11 1/4 inches in length by 2 3/4 inches in width, and has a depth of approximately 1 « inches. It is powered by 4 alkaline 1.5 Volt batteries.

The "Verifier" card key magnetic media entry device is imported in a door and a wall mounted version. This card reader contains an electronic circuit board with 128kb random access memory. It is capable of storing 300 operations in memory. This device records the data contained on the key cards for time of day and verification of the proper encryption code to permit the opening of the door's lock assembly. The lock assembly for this card key reader entry unit is obtained domestically.

The "Verifier" magnetic media card key reader entry device meets the definition of a "composite good" consisting of the electronic card key reader and part of the lock assembly which are described in different provisions of the HTS. Noting GRI-3(b), the components of this "composite good" are interconnected, adapted to each other, and mutually complementary. The "essential character" of this composite good would be exemplified by the electronic card key/magnetic media entry unit.

The applicable subheading for the "Verifier" card key magnetic media reader entry device will be 8471.90.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for other magnetic or optical readers. The rate of duty will be free.

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 Art Brodbeck at 212-466-5490.

Sincerely,

Robert B. Swierupski
Director,

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