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NY B82434




February 25, 1997

CLA-2-84:RR:NC:MA:110 B82434

CATEGORY: CLASSIFICATION

TARIFF NO.: 8471.80.1000

Mr. Steve Rhode
Fujitsu America, Inc.
1741 Junction Avenue
San Jose, CA 95112-1010

RE: The tariff classification of Channel and Processor Frames from Japan.

Dear Mr. Rhode:

In your letter dated February 18, 1997, you requested a tariff classification ruling.

The merchandise under consideration involves a mainframe computer that consists of two frames; the processor frame and the channel frame.

The processor frame, when completely assembled, contains:
a. One tightly coupled multi processor (TCMP) b. memory boards referred to as Super Integrated Memory Modules (SIMMs) c. Fan units which provide cooling for the operating TCMPs. d. A card cage, housing printed circuit assemblies, and various rectifiers and power converters.

The channel frame, when completely assembled, contains:
a. Service processor which consists of various processing and memory PCAs, hard and floppy disk drives, and a status panel allowing for system interface with the TCMPs. b. Channel Unit card cage and channel PCAs for interconnection to external devices such as direct access storage devices. c. Power input module, and EMI filter and circuit breaker panel.

The processor frame and the channel frame will be imported bolted together, and will now include the 6 additional (SVP) PCAs. The PCA-SCI provides the interface communication and testing function for the SVP and the different functional units in the mainframe.

The following PCAs make up the SVP:
a. PCA-SVP which was the subject of NY A89505 b. PCA-SCA which was the subject of NY A89484 c. PCA-SPC which was the subject of NY A89877 d. PCA SCI (System Console Interface), which provides the interface communication and testing function for the SVP and the different functional units in the mainframe. e. PCA-CLK (Clock), which provides the clock frequency signals for distribution to the TCMP (CPUs, main storage, secondary cache and memory control unit) and the Channel Subsystem (CHEs and IOPAs). f. The PCA-SPCE (System Power Controller Extender), extends the monitoring and control signals of the SPC to Frame C of the Mainframe.

The processor frame and the channel frame will be imported bolted together, but will lack the additional Frame C, PEP, SIMMS, and the TCMP's. The PCAs are adapter type of boards, and when used with the TCMP, provide the link to physical Input/Output devices and link to the System Control Console.

Noting Legal Note 5(A) to Chapter 84 of the HTS, and GRI-2(a), in the condition as imported, the two frames, imported with the service processor PCA's, would not appear to meet the definition of digital processing machine. The frames lack the "essential character" of a digital processing machine since they lack the PEP, SIMMS, and the TCMPs.

The two frames, imported with the service processor PCA's, do however meet the definition of a "unit" of an ADP system as defined in Legal Note 5(B) to Chapter 84 of the HTS. They are connectable to the central processing unit either directly or through one or more other units, and are specifically designed as part of such a system. The principal function of the Channel and Processor Frames, imported with the Channel PCA's, appears to be for the interconnection of mainframe's TCMP to other input and output units. It would thus fall under the definition of a control or adapter unit under HTS number 8471.80.1000.

The applicable subheading for the processor and channel frames, imported with the service processor PCA's, will be 8471.80.1000, 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.

This ruling is being issued under the provisions of Part 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,

Robert B. Swierupski
Chief, Metals & Machinery Branch

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