Classification of authentication security device under heading 8471 turns on CPU connectivity, data handling, and tariff exclusions.

A hardware authentication security device was held classifiable under Tariff Item 8471 80 00 as a unit of an automatic data processing machine. Applying Note 6 to Chapter 84 and the HSN guidance for heading 8471, the ruling found the device connectable to a CPU, capable of operating with computers, tablets and smartphones, and able to accept and deliver data in command form used by the system. The exclusions in Note 6(D) and Note 6(E) were found inapplicable because the device was not treated as a machine performing a separate specific function outside data processing. Contrary classifications and foreign rulings were not accepted as overriding the tariff analysis.

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Issues: Whether the product, a hardware authentication security device, is classifiable under Tariff Item 8471 80 00 as a unit of an automatic data processing machine.

Analysis: The ruling applied Note 6 to Chapter 84 of the Customs Tariff Act, 1975 and the HSN explanatory guidance for heading 8471. The product was found to be connectable to a CPU, to operate with computers, tablets and smartphones, and to accept and deliver data in the form of commands used by the system. The exclusion in Note 6(E) was held inapplicable because the product was not treated as a machine performing a specific function outside data processing, and the cited exclusions in Note 6(D) were also found not to cover it. Reliance placed on contrary classification under heading 8523 and on foreign rulings was not accepted as displacing the tariff analysis.

Conclusion: The product satisfies the conditions for classification as a unit of an automatic data processing system and is classifiable under Tariff Item 8471 80 00.

Ratio Decidendi: A separately presented device is classifiable under heading 8471 only if it is of a kind solely or principally used with an automatic data processing system, is connectable to the CPU, can accept or deliver usable data, and is not excluded by Note 6(D) or 6(E).

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