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NY 892297




November 22, 1993

CLA-2-84:S:N:N1 892297

CATEGORY: CLASSIFICATION

TARIFF NO.: 8471.93.6000; 8473.30.4000

Mr. Bud Coppersmith
L.E. Coppersmith, Inc.
3460 Wilshire Blvd. # 700
Los Angeles, CA 90010

RE: The tariff classification of optical storage devices, recordable CD ROM drive, chassis for hard drive, and a power module for the drive unit from Japan.

Dear Mr. Coppersmith:

In your letter dated October 22, 1993, on behalf of Pinnacle Micro, you requested a tariff classification ruling.

The merchandise under consideration involves three models of optical drive units, the chassis for one of these optical hard drive units, and a power module for the drive unit.

The Pinnacle Sierra 1.3GB optical hard drive is a high performance, external, magneto-optical drive unit that is ideal for data intensive applications such as desktop publishing, multimedia, corporate archival, and digital audio/video functions. This unit can hold up to 1.3GB of mass storage on a single cartridge, has a housing around the drive unit, and weighs 7.4 pounds.

The RCD-202 recordable CD-ROM drive unit is a recordable CD drive unit that is designed for use with Macintosh and PC computers. It comes complete with a software program that allows the user to produce data or audio CD's within minutes, in addition to its storage capability. This unit has a 12V power supply, is a free-standing external unit with a cabinet, incorporates a 50 pin SCSI connector, and is basically a 5.25" half-height write-once CD- ROM drive.

The Pinnacle Tahoe portable 3.5" optical drive unit is an external 128 MB optical drive unit that weighs 1.8 pounds. It is removable and transportable and provides portable storage capability for notebook and desktop computers. This storage unit is SCSI compatible and comes with an optional battery pack that provides 3.5 hours of portable computing.

The chassis for the Sierra 1.3 optical hard drive unit is the outer housing of this drive unit and is 186 mm in width, 254 mm in depth, and 93 mm in height. It appears to be constructed of plastic material.

The applicable subheading for the three models of optical drive units 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 a system. The duty rate will be 3.7 percent ad valorem.

The applicable subheading for the Sierra optical hard drive chassis 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 duty rate will be free.

Your inquiry does not provide enough information for us to give a classification ruling on the power module for the Tahoe optical drive unit. Your request for a classification ruling should include specific details and literature on this power module. Is this unit a universal AC adaptor that has other applications, or is it a power supply that provides continuous power to the ADP unit and is under the control of the ADP processor unit? If a power supply is it designed and principally used with ADP machines and units thereof? Is this power supply a free- standing unit or is it internally mounted?

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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