Radio-frequency identification (RFID) is the use of an object (typically referred to as an RFID tag) applied to or incorporated into a product, animal, or person for the purpose of identification and tracking using radio waves. Radio-frequency identification is comprised of interrogators (also known as readers), and tags (also known as labels or transponders). Classification of readers/interrogators CBP tends to treat readers/interrogators as ADP units. Relatively recent CBP ruling, NY M84377 (2006), classified RFID reader in the residual category of output units. The RFID reader was a “complete, self contained, freestanding unit that is connectable to other systems by a cable.” Therefore, CBP concluded “the card reader is classified as a separated unit that uses contactless technology provided for under heading 8471.” The problem with NY M84377 lies with the fact that the reader in question fails to meet ADP unit criteria under legal note 5(C)(i) – The unit is to be regarded as being part of ADP if it is of a kind solely or principally used in ADP processing system. The reader in question was for point-of-sale system, which are specifically provided under 8470.50.0020 (HTSUS 2010). The point-of-sale system is usually pre-programmed technology, and therefore, fails ADP requirement…
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