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NY B84953




May 28, 1997

CLA-2-84:RR:NC:1:110 B84953

CATEGORY: CLASSIFICATION

TARIFF NO.: 8471.80.1000

Mr. Nic Adams
Fritz Companies, Inc.
3109 Neil Armstrong Boulevard
Eagan, MN 55121

RE: The tariff classification of a "Zip-Up" device from Canada

Dear Mr. Adams:

In your letter dated May 21, 1997, on behalf of Miram International, Inc., you requested a tariff classification ruling.

The merchandise under consideration involves a Zip-Up device that is designed and used to connect a personal computer to an external Zip drive.

The Zip-Up device consists essentially of a PCMCIA card that is connected to a cable which in turn is connected to a micro management unit incorporated in the cable connector which plugs into the rear of a Zip drive. This enables the user to power his drive through the Notebook's PCMCIA slot, thus avoiding the need of an AC adapter, while on the move. The PCMCIA interface card allows true 16 bit data transfer with the Notebook computer. It is thus basically a PCMCIA to SCSI interface converter device.

Noting Legal Note 5 (B) to Chapter 84 of the HTS, this device would meet the definition of a "unit" of an ADP system, and performs an interconnection function between a computer and a storage drive.

The applicable subheading for the Zip-Up device will be 8471.80.1000, Harmonized Tariff Schedule of the United States (HTS), which provides for control or adapter units. 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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