HQ 0083188 - "Magnet Picturebase" image data processing system consisting of the following components: processor unit, image data compressor unit, disk controller, Winchester drive units, tape archive unit, visual display CRT unit(s) (VDU), dot matrix printer unit and keyboard(s). - United States International Trade Commision Rulings

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HQ 083188

February 22, 1990

CLA-2 CO:R:C:G 083188 MBR

CATEGORY:,CLASSIFICATION

TARIFF NO.:, 8471.91.00, 8471.99.15, 8471.93.20, 8471.93.60, 8471.92.65, 8471.92.40, 8471.92.20

Mrs. Nadine D. Silsbee
Brain A. Hill & Company, Inc.
Hill Cargo Facility
Logan Airport
East Boston, Massachusetts 02128

RE: "Magnet Picturebase" image data processing system consisting of the following components: processor unit, image data compressor unit, disk controller, Winchester drive units, tape archive unit, visual display CRT unit(s) (VDU), dot matrix printer unit and keyboard(s).

Dear Mrs. Silsbee:

This is in reply to your letter of August 10, 1988, on behalf of Crosfield Hastech, Inc., requesting classification of the Magnet Picturebase data processing system, under the Harmonized Tariff Schedule of the United States Annotated (HTSUSA).

FACTS:

The Magnet Picturebase system is a management information system that allows for networking capability, provides on-line archiving of compressed computer scanned images, which are stored on two or more (up to six) 340 megabyte winchester disk drives, has the ability to track jobs through the system and can gather productivity data. The system essentially consists of the following components: processor unit, image data compressor (processor) unit, disk controller, Winchester drive units, tape archive unit, visual display CRT unit(s) (VDU), dot matrix printer unit and a keyboard for each VDU.

ISSUE:

What are the classifications of the Magnet Picturebase data processing system under the Harmonized Tariff Schedule of the United States Annotated (HTSUSA)?

LAW AND ANALYSIS:

The General Rules of Interpretation (GRI's) to the HTSUSA govern the classification of goods in the tariff schedule. GRI 1 states, in pertinent part:

...classification shall be determined according to the terms of the headings and any relative section or chapter notes...

The processor unit meets the definition of a digital processing unit as defined in Chapter 84, Legal Note 5(A)(a), which states:

(A) For purposes of heading 8471, the expression "automatic data processing machines" means:

(a) Digital machines, capable of (1) storing the processing program or programs and at least the data immediately necessary for execution of the program; (2) being freely programmed in accordance with the requirements of the user; (3) performing arithmetical computations specified by the user; and, (4) executing, without human intervention, a processing program which requires them to modify their execution, by logical decision during the processing run;

Therefore, the processor unit is classifiable under subheading 8471.91.00, HTSUSA, which provides for: "[d]igital processing units, whether or not entered with the rest of the system, which may contain in the same housing one or more of the following types of units: storage units, input units, output units."

The image data compressor "compresses" (processes) image data in a ratio of 6:1 in order to increase the system's storage capabilities. Therefore, the data compressor is appropriately classifiable under subheading 8471.91.00, HTSUSA, which provides for: "[d]igital processing units, whether or not entered with the rest of the system...."

The disk controller is provided for specifically under subheading 8471.99.15, HTSUSA, which provides for: "[o]ther controller or adaptor units."

The winchester disk drive cabinet is a free-standing peripheral storage unit that houses up to three "trays," each containing two 340 Mbyte magnetic disk drives (i.e. from two up to six disk drives). The winchester disk diameter is aproximately 8" (i.e., over 21 cm in diameter).

Classification is therefore appropriate under subheading 8471.93.20, HTSUSA, when these large capacity disk drives are imported together as a unit. Subheading 8471.93.20, HTSUSA, provides for: "[s]torage units, whether or not entered with the rest of the system: [m]agnetic disk drive units: [f]or a disk of a diameter exceeding 21 cm: [o]ther."

The optional tape archive free standing peripheral unit, housed in its own cabinet, is classifiable under subheading 8471.93.60, HTSUSA, which provides for: "[s]torage units, whether or not entered with the rest of the system: [o]ther storage units: [o]ther."

The dot matrix printer is a complete output unit, that is assembled and includes at least the media transport, control and print mechanism. The printer is therefore classifiable under subheading 8471.92.65, HTSUSA.

The visual display(s) (up to 5 VDU's can be attached to the system) are free-standing output devices that incorporate a cathode-ray tube. Therefore, the VDU's are classifiable under subheading 8471.92.40, HTSUSA, which provides for: "[i]nput or output units...: [o]ther: [d]isplay units: [o]ther, with cathode- ray tube (CRT)."

The keyboard is a free-standing input device, dedicated for use with the digital processing machine of this system. Classification is thus appropriate under subheading 8471.92.20, HTSUSA, which provides for: "[i]nput or output units...: [o]ther: [k]eyboards."

HOLDING:

The processor unit is classifiable under subheading 8471.91.00, HTSUSA, which provides for: "[d]igital processing units, whether or not entered with the rest of the system, which may contain in the same housing one or more of the following types of units: storage units, input units, output units." The rate of duty is 3.9% ad valorem.

The data compressor (processor) is appropriately classifiable under subheading 8471.91.00, HTSUSA, which provides for: "[d]igital processing units, whether or not entered with the rest of the system..." The rate of duty is 3.9% ad valorem.

The disk controller is classifiable under subheading 8471.99.15, HTSUSA, which provides for: "[o]ther controller or adaptor units." The rate of duty is free.

Classification for the winchester disk drives, imported together as a unit, is appropriate under subheading 8471.93.20, HTSUSA. Subheading 8471.93.20, HTSUSA, provides for: "[s]torage units, whether or not entered with the rest of the system: [m]agnetic disk drive units: [f]or a disk of a diameter exceeding 21 cm: [o]ther." The rate of duty is 3.7% ad valorem.

The optional tape archive free standing peripheral unit, housed in its own cabinet, is classifiable under subheading 8471.93.60, HTSUSA, which provides for: "[s]torage units, whether or not entered with the rest of the system: [o]ther storage units: [o]ther." The rate of duty is 3.7% ad valorem.

The dot matrix printer is a complete output unit, that is assembled and includes at least the media transport, control and print mechanism. The printer is therefore classifiable under subheading 8471.92.65, HTSUSA. The rate of duty is 3.7% ad valorem.

The visual displays are a free-standing output device that incorporate a CRT. Therefore, the VDU's are classifiable under subheading 8471.92.40, HTSUSA, which provides for: "[i]nput or output units...: [o]ther: [d]isplay units: [o]ther, with cathode- ray tube (CRT)." The rate of duty is 3.7% ad valorem.

The keyboard is a free-standing input device, dedicated for use with the digital processing machine of this system. Classification is thus appropriate under subheading 8471.92.20, HTSUSA, which provides for: "[i]nput or output units...: [o]ther: [k]eyboards." The rate of duty is free.

Sincerely,

John Durant, Director

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