Portable data-processing devices classified as ADP machines, not communication apparatus, due to their principal enterprise functions.

Imported barcode mobile computers, RFID mobile computers and tablet mobile computers were classified under Heading 8471 as portable digital automatic data processing machines because they were rugged, portable, freely programmable, and capable of storing, executing and processing data through a CPU, display and keyboard or touchscreen. Their principal use was enterprise data processing, including scanning, RFID reading, inventory control and logistics tracking. Chapter Note 6(A) to Chapter 84 was satisfied, Chapter Note 6(C) did not apply because the goods were themselves ADP machines, and auxiliary SIM or wireless features did not make them communication apparatus. Classification under Heading 8517 was therefore rejected.

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Issues: Whether the imported Barcode Mobile Computers, RFID Mobile Computers and Tablet Mobile Computers are classifiable under Heading 8471, specifically sub-heading 8471 30 90, as portable digital automatic data processing machines, or under Heading 8517 as communication apparatus.

Analysis: Classification was determined by the General Rules of Interpretation, Chapter Notes and Section Notes to the Customs Tariff Act, 1975, together with the HSN Explanatory Notes. The devices were found to be rugged, portable and freely programmable, with a CPU, display and keyboard or touchscreen input, and designed primarily for enterprise data processing functions such as barcode scanning, RFID reading, inventory control, logistics tracking and other related applications. Chapter Note 6(A) to Chapter 84 was satisfied because the goods were capable of storing and executing programs, were freely programmable, and performed arithmetical and logical processing. Chapter Note 6(C) concerning units of an ADP system was held inapplicable because the devices were themselves ADP machines. Chapter Notes 6(D) and 6(E) were also found not to displace classification under Heading 8471. The presence of SIM-based or wireless communication features was treated as auxiliary and not indicative of a principal telephony function, and the principal function test under Note 3 to Section XVI supported classification according to the main data-processing character of the goods. The guidance contained in the CBIC circulars and the cited advance rulings reinforced this conclusion.

Conclusion: The goods are classifiable under Heading 8471 and sub-heading 8471 30 90 as other portable digital automatic data processing machines, and not under Heading 8517.

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