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March 11, 1999

CLA-2-85:RR:NC:N1:113 D88191

CATEGORY: CLASSIFICATION

TARIFF NO.:8302.41.9045; 8302.41.6045; 8471.90.0000

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

RE: The tariff classification of electronic card key entry device components from Spain

Dear Mr. Schau:

In your letter dated February 10, 1999, on behalf of Tesa Entry System, Inc., you requested a tariff classification ruling.

The merchandise is an electronic key card entry device. The Tesa Integra3 and HT24 card key readers contain a microprocessor and RAM. It is attached to the door and records the data contained on the key cards for time of day and access code.

The applicable subheading for the card key readers 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.

The door handle lever and exterior facia cover are sold separately from the Integra and HT24 Systems. They may be made of steel, aluminum or of brass. They do not contain a mechanical lock assembly.

The applicable subheading for the aluminum and steel handle and facia will be 8302.41.6045, Harmonized Tariff Schedule of the United States (HTS), which provides for base metal mountings, fittings and similar articles suitable for furniture, doors, staircases, windows, blinds, coachwork, saddlery, trunks, chests, caskets or the like, other mountings, fittings and similar articles, suitable for buildings, other, of iron or steel, of aluminum or of zinc, suitable for interior and exterior doors, other. The rate of duty will be 3.9 percent ad valorem.

The applicable subheading for the brass handle and facia will be 8302.41.9045, Harmonized Tariff Schedule of the United States (HTS), which provides for base metal mountings, fittings and similar articles suitable for furniture, doors, staircases, windows, blinds, coachwork, saddlery, trunks, chests, caskets or the like, other mountings, fittings and similar articles, suitable for buildings, other, other, suitable for interior and exterior doors, other. The rate of duty will be 3.5 percent ad valorem.

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 James Smyth at 212-637-7008.

Sincerely,

Robert B. Swierupski
Director

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