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NY 894426




February 7, 1994

CLA-2-84:S:N:N1:110 894426

CATEGORY: CLASSIFICATION

TARIFF NO.: 8471.92.1090

Ms. Ann Marie Dowling
Seino America, Inc.
147-60 175th Street
Jamaica, N.Y. 11434

RE: The tariff classification of a Portable Data Terminal and the plastic housing for such a unit from Singapore.

Dear Ms. Dowling:

In your letter dated January 25, 1994, on behalf of Symbol Technologies, Inc., you requested a tariff classification ruling.

The merchandise under consideration involves a model PDT 1475 Portable Data Terminal and the plastic housing for such a unit. The Data terminal is a hand-held device that is designed for data input and output functions for such applications as electronic ordering, sales order entry, and market research. The PDT 1475 has a 16 character alphanumeric LCD display, with 32K of RAM, a built-in Electronic Ordering System program, a numeric keyboard with 29 keys, and a modem all in one compact case.

The unit weighs less than one pound and will operate for up to 100 hours on a nine volt battery. The PDT can communicate to a host computer system via modem or through a RS 232C interface. The unit incorporates a Hitachi 6303 microprocessor, has a Terminal Operating System (TOS) stored in 32K EPROM, and allows for data capture through a laser scanner or wand in addition to the keyboard.

Noting Legal Note 5 (A) (a) to Chapter 84 of HTS, this device would not meet the definition of a digital processing machine. It however meets the definition of a "unit" of an ADP system, noting LN 5 (B) to Chapter 84.
The plastic housing for this combined input/output unit appears to be specially designed and principally used with this device.

The applicable subheading for the PDT 1475 Portable Data Terminal will be 8471.92.1090, Harmonized Tariff Schedule of the United States (HTS), which provides for combined input/output units, whether or not entered with the rest of a system and whether or not containing storage units in the same housing. The rate of duty will be 3.7 percent ad valorem.

The applicable subheading for the plastic housing for the PDT 1475 will be 8473.30.5000, HTS, which provides for other 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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