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NY 813723




August 18, 1995

CLA-2-84:S:N:N1:110 813723

CATEGORY: CLASSIFICATION

TARIFF NO.: 8471.99.1500; 8473.30.5000

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

RE: The tariff classification of components for model DKC2101 controller units and a laptop computer 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 controller units; components and subassemblies of the controller units, and a laptop computer. The controller unit consists of a complete and assembled model DKC2101. Stage 1 of these shipments will consist of the complete and assembled DKC2101. In Stage 2, and Stage 3, the shipments will consist of parts and sub- assemblies of the DKC unit. All of the "S" parts will be shipped separately from the "L" and "M", and will be classified individually in accordance with GRI-1. A laptop computer will also be imported as an "S" part.

The DKC2101 is the controller unit for Hitachi's 7700 Array Storage Subsystem. This system uses an enhanced 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 DKC2101 is a controller which performs as an interface between the subsystem's storage unit and the CPU. It is functionally inseparable from the storage unit. The DKC basically performs only data transfer functions. The DKC2101 is an upgrade of the DKC901-3 model, which was the subject of N.Y. Ruling 886517.

The control system for the DKC2101 is different from that in prior controllers. The hard disk drive and the floppy disk drive and boards of the DKC901-3 have been replaced with a laptop computer.

During Stage 1, the DKC2101 will be imported in its complete and assembled form. In Stage 2 and Stage 3 the parts and subassemblies necessary for the subassembly manufacturing and final DKC assembly in the United States will be imported. The parts and subassemblies will be in imported in large ("L"), medium ("M") and small ("S") parts groups.

The "L" parts will consist of: 1 - the larger sheet metal parts of the DKC2101. These parts constitute the DKC's frame. In Stage 2 and Stage 3 the "L" parts will consist of the frame assembly, front and rear door assemblies, and the side cover assembly.

In Stage 2, the "M" parts will consist of the back panel assembly and the printed circuit board assembly. The printed circuit board parts are Single In line Memory Modules ("SIMMS") which are printed circuit boards populated with several DRAMS. In Stage 3, the "M" parts will consist of only the back panel assemblies.

The "S" parts in Stage 2 and Stage 3 will consist of the smaller parts necessary for subassembly and final DKC manufacture in the United States. The "S" parts will include parts used by Hitachi to produce the DKC including: the wire harness, printed circuit board assemblies, the power supply assembly, and the mechanical service assembly. All of the "S" parts will be shipped separately from the "L" and the "M" parts, and will be classified individually in their appropriate HTS provision in accordance with GRI-1. A laptop computer will be imported as a "S" part.

The applicable subheading for the complete and assembled DKC2101 will be 8471.99.1500, Harmonized Tariff Schedule of the United States (HTS), which provides for other control or adapter units for use with automatic data processing machines. The rate of duty will be free.

The applicable subheading for the "L" parts and the "M" parts which consist of the cabinet, frame, similar sheet metal parts, and the "M" parts which consist of the back panel assembly and printed circuit boards or SIMMS 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.

Your inquiry does not give us enough information for us to give a classification ruling on the laptop computer. Your request should include descriptive literature of this laptop computer. Are all the components of this laptop computer in one common housing? We also need a clarification of your reference to a monochrome monitor. Is this a separate unit, or is this monochrome monitor an integral component of the laptop computer?

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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