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NY 881185




December 17, 1992

CLA-2-84:S:N:N1:110 881185

CATEGORY: CLASSIFICATION

TARIFF NO.: 8471.93.6000; 8473.30.4000

Mr. Paul Donatelli
Hitachi Transport System (America), Ltd.
2459 West 208th Street
Torrance, CA 90501

RE: The tariff classification of a model MTU505 magnetic tape unit and component parts from Japan.

Dear Mr. Donatelli:

In your letter dated December 14, 1992, you requested a tariff classification ruling.

The merchandise under consideration involves a model MTU550 magnetic tape unit that is a part of a magnetic tape subsystem (MT500). A magnetic tape subsystem is primarily used as a backup storage system, and consists of a magnetic tape controller (MTC) and magnetic tape units (MTU). The MTU505 model incorporates four tape drives per cabinet.

This storage unit performs the following functions: 1. responds to commands from the MTC; 2. loads or unloads the cartridge tape; 3. positions the tape; 4. reads or writes data on the tape; and 5. performs diagnostic evaluation of the tape unit. The MTU records data on a magnetic tape housed in a small cartridge. The tape has a storage capacity of up to 1,200 MB/vol., at 75% data compression.

The MTU505 storage unit will be imported in its first stage as a complete and assembled unit. In stage two, the shipments will be imported in "S", "L", and "M" groups, with the L and M groups usually together and the S group separate. The "L" group parts are generally the larger parts such as the cabinet and drive frame. The "M" group parts include various subassemblies used in the final assembly of the MTUs, such as the head guide assembly. The "S" group parts are generally small parts that are used for making the MTU subassemblies. One specific "S" part, which is comparable to an "M" part back panel, and described as four main P/K mount assemblies, are used to hold the PCBs in place and connect them to the system.

The applicable subheading for the complete and finished MTU505 in Stage one will be 8471.93.6000, Harmonized Tariff Schedule of the United States (HTS), which provides for other storage units, whether or not entered with the rest of the system. The rate of duty will be 3.7 percent ad valorem.

The applicable subheading for the "L" and "M" components and assemblies under Stage two will be 8473.30.4000, HTS, which provides for parts and accessories of the machines of heading 8471, not incorporating a cathode ray tube. The rate of duty will be free.

The applicable subheading for the "S" part, a main P/K mount assembly, and any other "S" parts in Stage two that are not more specifically provided for under Legal Note 2 (a) to Section 16 of HTS, will be 8473.30.4000, HTS, which provides for parts and accessories of the machines of heading 8471, not incorporating a cathode ray tube. The rate of duty will be free.

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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