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NY 852239


May 10 1990

CLA-2-84:S:N:N1:110 852239

CATEGORY: CLASSIFICATION

TARIFF NO.: 8471.92.30; 8473.30.40; 8471.92.20; 8507.80.00; 8471.99.30; 8471.93.30

Mr. Frederick L. Ikenson
1621 New Hampshire Avenue, N.W.
Washington, D.C. 20009

RE: The tariff classification of computer parts from Japan.

Dear Mr. Ikenson:

In your letter dated May 2, 1990, on behalf of Zenith Data Systems, you requested a tariff classification ruling.

The merchandise under consideration consists of component parts for a model "M-4SV" lap top computer. These components will be shipped separately and do not represent an unassembled or unfinished computer. The shipments will consist essentially of four major subassemblies, which after importation will be assembled in the United States.

Group 1 consists of a plastic cabinet top that houses the liquid chrystal display unit and its assorted electronics. Also included is the plastic cabinet bottom with speaker and EMI shields, and other plastic parts such as the cover for the modem cavity and the battery. This group also includes a keyboard assembly, that is comprised of a keyboard, and a printed circuit board with a flat cable.

Group 2 consists of nine assemblies or components, which include the following: a main printed circuit board without the CPU chip and ROM BIOS; light emitting diode board; switch printed circuit board; metal bracket to keyboard; metal bracket to modem; lithium battery; AC adapter without line cord; two shield plates; and miscellaneous metal parts that includes fixers, screws, clamps, spacers, and a plate spring.

Group 3 consists of a metal bracket for the hard disk drive top.

Group 4 consists of an internally mounted floppy disk drive unit, metal bracket for the drive unit, and a cable for the drive unit.

The applicable subheading for the LCD assembly and plastic top/bottom asssembly will be 8471.92.3000, Harmonized Tariff Schedule of the United States (HTS), which provides for display units without cathode-ray tube (CRT), having a visual display diagonal not exceeding 30.5 cm. The rate of duty will be free. The applicable HTS subheading for the cabinet bottom with speaker and EMI shield, and the other plastic parts will be 8473.30.4000, which provides for parts and accessories of the machines of heading 8471, and are free of duty. The applicable HTS subheading for the keyboard assembly will be 8471.92.2000, which provides for keyboards, and is free of duty.

The applicable HTS subheading for the Group 2 sub-assemblies and components are as follows: the main printed circuit board (without the CPU and ROM BIOS), the LED printed circuit board, the switch printed circuit board, the metal brackets for the keyboard and modem, the two shield plates, and the metal parts such as the fixers, plates, spacers, and clamps, are all classifiable under HTS number 8473.30.4000, which provides for parts and accessories of the machines of heading 8471, and are free of duty. The applicable HTS subheading for the lithium battery will be 8507.80.0000, which provides for other storage batteries, and dutiable at the rate of 5.1 percent ad valorem. The A.C. adaptor without line cord (power supply) is classifiable under HTS number 8471.99.3000, which provides for power supplies, and dutiable at the rate of 3 percent ad valorem.

The applicable HTS subheading for the Group 3 merchandise (metal bracket for the hard disk drive) will be 8473.30.4000, which provides for parts and accessories of the machines of heading 8471, and is free of duty.

The applicable HTS subheading for the Group 4 merchandise (floppy disk drive assembly) will be 8471.93.3020, which provides for flexible (floppy) disk drive units, not assembled in cabinets, and without attached external power supply, and is free of duty.

This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177).

A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction.

Sincerely,

Jean F. Maguire
Area Director

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