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February 23, 1999

CLA-2-84:RR:NC:1:110 D88259

CATEGORY: CLASSIFICATION

TARIFF NO.: 8471.90.0000

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

RE: The tariff classification of a Portable Programmer 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 under consideration involves a portable programmer device that is part of a keyless card security system commonly found in hotels and commercial applications used for room entry service.

The portable programmer is basically a portable data recovery unit, and is used to download individual entrance location information from the card readers attached to the entrance doors. It is battery operated and reads the encoded data record of key card swipes. It is approximately 4" in width, 7" in length, and 1 1/2" in depth, and has a memory capacity of 128k RAM. It also contains an Intel 80C31 microprocessor. The programmer stores the data recovered from remote card key readers attached to doors. The user simply connects the programmer to the card key reader on the door by a cable and transfers the electronic data in the form of digital information, to the programmer. The recovered data can then be viewed on the LCD display of the programmer and stored or processed onto the card encoder unit.

The principal function of this device appears to be for transcribing data onto data media in coded form, and would thus fall under the Part 2 provision of heading 8471. Please note also HQ ruling 957416 and NY ruling D81084 for similar merchandise.

The applicable subheading for the portable programmer will be 8471.90.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for other machines for transcribing data onto data media in coded form and machines for processing such data, not elsewhere specified or included. 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 212-637-7019

Sincerely,

Robert B. Swierupski
Director,

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