Portable data-processing machines retain heading 8471 classification where communication features are only ancillary to enterprise computing functions.

Mobile computers, tablet computers and vehicle-mounted computers were treated as portable automatic data-processing machines under CTI 84713090 because they satisfied Note 6(A) to Chapter 84: they had storage, programmability, arithmetic processing capability and could execute programs without human intervention. Their barcode scanning, data capture and enterprise software functions showed they were independent ADP machines, so Notes 6(C), 6(D) and 6(E) did not alter classification. Ancillary communication or SIM-enabled features did not make them smartphones, as their dominant character remained rugged enterprise data-processing equipment.

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Issues: Whether Mobile Computers, Tablet Computers and Vehicle Mounted Computer are classifiable under CTI 84713090 as portable automatic data-processing machines, or under heading 8517 / as smartphones.

Analysis: The classification turned on whether the goods satisfied the conditions for automatic data-processing machines under Note 6(A) to Chapter 84 of the Customs Tariff Act, 1975. The devices were found to have the required storage, programmability, arithmetical processing capability, and ability to execute processing programs without human intervention. Their barcode scanning, data capture, and enterprise software functions showed that they were independent ADP machines and not merely units of an ADP system, so Note 6(C) did not govern their classification. Notes 6(D) and 6(E) were also held inapplicable because the goods were not merely apparatus working in conjunction with ADP machines to perform a different specific function. Applying the HSN Explanatory Notes and the rule of principal function under Section Note 3 of Section XVI of the Customs Tariff Act, 1975, the devices were treated as portable ADP machines whose communication or SIM-enabled features were only ancillary or supplementary. They were further held not to be smartphones, because their design and commercial identity were that of rugged enterprise computers used primarily for data processing and scanning, not telephony.

Conclusion: The goods are classifiable under CTI 84713090 and not under heading 8517, and the ruling is in favour of the applicant.

Ratio Decidendi: Where a device's dominant character is that of a freely programmable portable data-processing machine, ancillary communication features do not shift classification away from heading 8471.

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