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NY 876129


August 03, 1992

CLA-2-84:S:N:N1:103 876129

CATEGORY: CLASSIFICATION

TARIFF NO.: 8428.90.0010

Mr. Scott Rodman
Storage Technology Corporation
2270 South 88th Street
Louisville, CO 80028-0001

RE: The tariff classification of a tape cartridge robot from a foreign trade subzone

Dear Mr. Rodman:

In your letter dated June 29, 1992 you requested a tariff classification ruling.

The tape cartridge robot will be used as a component of the Model 4400 Automated Cartridge System, a machine used for mass storage and automatic retrieval of digital information. The Model 4400 utilizes up to sixteen interconnected library storage modules (LSM's), each of which can hold up to 1200 gigabytes of data. The data is stored on magnetic tape cartridges individually arrayed in rows along the periphery of the enclosed LSM unit. The robot contains a solid-state camera and two mechanical hands, each of which has a light mounted on it. Utilizing the camera and lights the robot locates the proper cartridge by reading a barcoded volume serial number which is marked on the spine of each cartridge. One hand of the robot then removes the cartridge from its storage cell in the LSM, carries it to a tape transport drive and loads it into the drive. Simultaneously, the other hand removes the tape cartridge which was previously loaded into the drive and returns it to the LSM.

In a telephone conversation with a member of my staff, you stated that the encoder motor for the robot will be imported from Japan. The balance of the components of the robot are of American origin. The Japanese motor and American components will be assembled together in your plant, which is currently awaiting approval as a foreign trade subzone. You will enter the robot into the customs territory of the United States directly from the foreign trade subzone and have requested a ruling as to the tariff classification of the assembled robot.

The applicable subheading for the tape cartridge robot will be 8428.90.0010, Harmonized Tariff Schedule of the United States (HTS), which provides for other lifting, handling, loading or unloading machinery: other machinery: other: industrial robots. The rate of duty will be 2 percent ad valorem.

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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