Automatic data processing machine classification upheld for an integrated interactive flat panel with built-in processing functions.

An interactive flat panel with in-built CPU, memory, storage and Android operating system was classified as an automatic data processing machine under heading 8471 rather than as a monitor under heading 8528. The classification was determined by the tariff description, Chapter Notes to Chapter 84, and Rules 1 and 6 of the General Rules for Interpretation. Because the product had independent processing capability, programmable operation and integrated data-processing functions, its display and touch features were treated as incidental. The result was classification under sub-heading 84714190, reflecting that the device was not merely a monitor working with another machine but a self-contained data-processing system.

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Issues: Whether the proposed import of an interactive flat panel with in-built CPU, memory, storage and android operating system is classifiable as an automatic data processing machine under heading 8471 or as a monitor under heading 8528.

Analysis: The classification turned on the tariff description, the Chapter Notes to Chapter 84, and the General Rules for Interpretation. The goods were found to contain the essential components of an automatic data processing machine, including processing capability, memory, storage, and software that enabled independent and programmable operation. The presence of display and touch functionality did not displace the broader character of the product, because the item was not merely a monitor acting in conjunction with another machine, but an integrated system capable of data processing in its own right. The reasoning also applied Rule 1 and Rule 6 of the General Rules for Interpretation, and treated the specific description and capabilities of the product as decisive for classification.

Conclusion: The goods are classifiable under sub-heading 84714190 and not under heading 8528.

Final Conclusion: The proposed product was held to be an automatic data processing machine for tariff purposes, so the applicant's claimed classification was accepted.

Ratio Decidendi: A product with in-built processing unit, memory, storage and freely programmable operating capability is classifiable as an automatic data processing machine when its display feature is incidental to its integrated data-processing function.

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