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NY 813671




August 18, 1995

CLA-2-84:S:N:N1:110 813671

CATEGORY: CLASSIFICATION

TARIFF NO.: 8471.93.4050; 8473.30.5000

Mr. Kenneth Weigel, Esq.
Kirkland & Ellis
655 15th Street, N.W.
Washington, D.C. 20005

RE: The tariff classification of components for model DKU2051 disk storage units from Japan.

Dear Mr. Weigel:

In your letter dated August 8, 1995, on behalf of Hitachi Computer Products (America), Inc., you requested a tariff classification ruling.

The merchandise under consideration involves complete disk storage units, and components and subassemblies of the disk storage units. The magnetic disk storage consists of a complete and assembled model DKU2051. Stage 1 of these shipments will consist of the complete and assembled DKU2051 disk storage unit. In Stage 2, and Stage 3, the shipments will consist of parts and subassemblies of the DKU unit, and will be described as the "L" group and the "M" group components. All of the "S" parts will be shipped separately from the "L" and "M" parts, and will be classified individually in accordance with GRI-1.

The DKU2051 is the disk drive unit for Hitachi's 7700 Array Storage subsystem. This subsystem uses a Redundant Array of Independent Disks ("RAID") design which allows for continuous storage, backup and maintenance of the subsystem without having to take the system down. The DKU2051 uses 3.5 inch disk drives compared with the 6.5 inch disk drives in the DKU-881. The storage capacity in the DKU2051 will be 3.78GB per HDA per unit. The DKU2051 will be able to have up to 56 Head Disk Assemblies ("HDA") in each unit.

During Stage 1, the DKU2051 will be imported in its complete and assembled form. In Stage 2 and Stage 3 the parts and subassemblies necessary for subassembly manufacturing and final DKU assembly in the United States will be imported. The parts and subassemblies will be imported in large ("L"), medium ("M") and small ("S") parts groups.

The "L" parts will consist of: 1 - sheet metal parts for the frame and door assemblies for the DKU2051; 2 - the HDU box assembly which consists of sheet metal parts for the HDU box. The HDU box assembly will contain up to seven HDAs. At the time of importation, it may contain HDAs temporarily mounted in it for shipment. 4 - HDAs. A HDA consists of the platter, head, voice coil motor and spindle motor in an enclosed housing. After importation, a fan and a bracket are added to the HDA. To transform a HDA to a HDU, a read/write or drive main board and DC to DC converter are added to the HDA. There will be two power supplies per HDU box for up to 7 HDAs. The power supplies will be produced in the United States.

In stage two, the "M" parts will consist of the back panel assembly. In stage three, these assemblies will be manufactured in the United States. There will be no "M" parts in stage three.

The applicable subheading for the complete and assembled DKU2051 will be 8471.93.4050, Harmonized Tariff Schedule of the United States (HTS), which provides for other hard magnetic disk drive units. The rate of duty will be 3 percent ad valorem.

The applicable subheading for the "L" parts, which consist of the sheet metal frame metal assembly for the frame and door assembly for the DKU2051; the sheet metal parts for the HDU box assembly, and the "M" parts which consist of the back panel assembly, will be 8473.30.5000, Harmonized Tariff Schedule of the United States (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 HDAs must also be classified as parts under item 8473.30.5000 (HTS). The HDAs as imported do not contain the read/write board nor the power supplies. Without these components, the HDAs lack the essential character of a disk drive unit and thus cannot be classified as such.

Therefore, the applicable subheading for the HDAs will be 8473.30.5000, Harmonized Tariff Schedule of the United States (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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