Automatic data processing machine: interactive flat panels with CPU, memory and touch I/O classified under ADP tariff heading.

Interactive flat panels incorporating a central processing unit, memory, an operating system, touch input and LED output in a single housing meet the criteria of an automatic data processing machine under Chapter Note 6(A) to Chapter 84 because they store programs/data, are freely programmable (including via an OPS module), perform computations and execute conditional processing; accordingly they are classifiable as ADP machines rather than mere monitors and fall within the tariff sub heading for automatic data processing machines. Application of the chapter note and the primary interpretative rule governs classification without recourse to other GRI provisions.

---

---

Issues: Whether the imported ViewSonic Interactive Flat Panels (IFP) (various models) are classifiable as automatic data processing machines under Sub-heading 8471.41.90 of the Customs Tariff Act, 1975 or as monitors under Chapter 85 (heading 8528).

Analysis: The item has an in-built central processing unit, memory (RAM and storage), an operating system (embedded Android with capability to accept additional OS via OPS module), input (touch-sensitive surface) and output (LED display) units within the same housing. The item meets the conditions set out in Chapter Note 6(A) to Chapter 84 for an automatic data processing machine, namely storing programs/data, being freely programmable to the extent supported (including by adding an OPS module), performing arithmetical computations and executing processing programs that modify execution by logical decision during a processing run. The term "interactive" and the combined presence of processing, input and output units bring the product within the scope of heading 8471. Application of Rule 1 and Note 6 of Chapter 84 governs classification without recourse to other GRI provisions. Relevant international and domestic rulings on substantially similar interactive flat panel products support classification under heading 8471.41.90 rather than as a monitor under heading 8528 where the primary function is merely display.

Conclusion: The ViewSonic Interactive Flat Panels (IFP) (specified models) are classifiable under Sub-heading 8471.41.90 of the Customs Tariff Act, 1975 in favour of the appellant.

Ratio Decidendi: A product comprising in the same housing a central processing unit together with input and output units that satisfies Chapter Note 6(A) to Chapter 84 is an automatic data processing machine and is classifiable under Sub-heading 8471.41.90 of the Customs Tariff Act, 1975.

---