In the Aug. 31, 2022, Customs Bulletin and Decisions, U.S. Customs and Border Protection is proposing to reclassify a universal bill stacker sub-assembly designed to receive and store paper currency in gaming, vending, and other machines as a banknote measuring machine under HTSUS 9031.49.90 (duty-free) rather than as a part of a gaming machine operated by banknotes under HTSUS 9504.30.0060 (duty-free).

CBP states that its original classification was based on the petitioner’s assertion that the subject item, given the substantial construction of the housing and the locks used with the item, is principally used with casino gaming machines. However, CBP now states that these physical characteristics do not prevent the item from being used in general vending machines.

“Although we recognize the [item’s] gaming-specific design and features,” CBP said, “the evidence of a single importer’s design for or sale to the gaming industry does not demonstrate the actual principal use of the merchandise.” In addition, CBP said, this item “is not an essential part of casino gaming machines as it does not enable the gaming function or facilitate the operation; instead, it performs a distant function.”

Ruling NY I86148 would be revoked to reflect this change. Comments on this proposal are due no later than Sept. 30.

For more information on how to seek or utilize classification and other rulings, please contact attorney Deb Stern at (305) 894-1007 or via email.

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