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NY 816160




October 31, 1995

CLA-2-84:R:N1:110 816160

CATEGORY: CLASSIFICATION

TARIFF NO.: 8473.30.5000; 8504.40.8004

Mr. Richard J. Houseman
Sharp Microelectronics Technology, Inc.
5700 NW Pacific Rim Boulevard
Camas, Washington 98607

RE: The tariff classification of a subassembly for a notebook computer, and an A/C Adapter from Taiwan.

Dear Mr. Houseman:

In your letter dated October 20, 1995, you requested a tariff classification ruling.

The merchandise under consideration involves a subassembly for a notebook computer and an A/C adapter that will be combined with components from the U.S. to produce a finished notebook computer.

The importation from Taiwan will consist of the following components:

1. Plastic cabinet for computer, including built-in keyboard and frame for LCD display, together with the necessary structural components. 2. Complete electronics system of the computer (main board, etc) with the exception of the CPU chip. 3. Cardboard box suitable for retail packaging of finished notebook computer. 4. A separate A/C adapter.

The cabinet for the computer, and electronics are all physically attached to each other, thus creating a subassembly. The A/C adapter is a separate unit that plugs into the computer and wall outlet. The components missing from this unfinished notebook computer are the LCD display, the removable hard disk drive, the battery pack, and the CPU chip. This subassembly will be imported under model number PC-3010.

In its imported condition, this subassembly, or unfinished notebook computer, lacks the CPU chip, which is the principal component of the digital processing unit. It thus does not have the essential character of a finished digital processing unit, as per Legal Note 5 (A) to Chapter 84 of the HTS, and GRI-2 (a). Noting HQ rulings 954307, 957178, and 954411, this subassembly would therefore be classifiable as a part of an ADP system, since Customs also previously ruled that in its imported state as a subassembly, such merchandise also did not have the essential character of any of their constituent components (units) or parts.

The A/C adapter being a separate and distinct article, and not physically attached to the subassembly, would be separately classifiable.

The applicable subheading for the PC-3010 notebook subassembly will be 8473.30.5000, Harmonized Tariff Schedule of the United States (HTS), which provides for other parts of the machines of heading 8471. The rate of duty will be free.

The applicable subheading for the A/C adapter will be 8504.40.8004, HTS, which provides for other rectifiers and rectifying apparatus, power supplies, with a power output not exceeding 50 W. The rate of duty will be 2.7 percent ad valorem. This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177).

A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist Art Brodbeck at 212-466-5490.

Sincerely,

Roger J. Silvestri
Director

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