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NY B86602





June 23, 1997

CLA-2-84:RR:NC:1:110 B86602

CATEGORY: CLASSIFICATION

TARIFF NO.: 8473.30.1000; 8473.30.5000; 8471.70.6000

Ms. Machiko Celli
Nippon Express U.S.A., Inc.
P.O. Box 2487
South San Francisco, CA 94083-2487

RE: The tariff classification of Notebook Computer subassembly from Japan.

Dear Ms. Celli:

In your letter dated June 10, 1997, on behalf of Sotec America, Inc., you requested a tariff classification ruling.

The merchandise under consideration involves a "Sotec Z1 Series" Notebook subassembly for a Notebook Computer, a CPU daughter board, and a CD-ROM module for this "Sotec Z1 Series" subassembly. The components for this Notebook computer subassembly will be imported in varying configurations

The Main Unit", which is known as model KZ1-PXXXXX-MAIN01, is a printed circuit board that measures 11.7 inches in width by 8.8 inches in depth, and has a height of 1.56 inches. The Main Unit consists of electrical circuits, a LCD display, a keyboard, a battery pack, an AC Adapter, and a FDD unit excluding a CPU daughter board and a CD-ROM module. Although it does not contain a CPU chip, it does contain a BIOS chip.

The "CPU Daughter Board", which is known as model KZ1-XXXCPPUA-CPUBD01, is a printed circuit board that measures 3.54 inches in length by 2.28 inches in width, and has a height of 0.43 inches. This daughter board contains a CPU chip, SRAM, and some related peripheral circuits, but is without the BIOS chips.

The "CD-ROM Module", which is known as KZ1-X10CDR-CDROM1, measures 5.15 inches in length by 5.14 inches in width, and has a height of 0.54 inches. This X10 speed "CD-ROM Module is enclosed in a plastic module case, but is designed for internal use. It has an average transfer rate of X10.

These Notebook Computer subassemblies do not have the "essential character" of a complete or finished digital processing unit, noting GRI-2(a) of the Harmonized Tariff Schedule, and Legal Note 5(A) to Chapter 84 of the HTS. Note also HQ ruling letters 954411 and 957178, and NY Ruling letters B85751 and B80848.

The applicable subheading for the model KZ1-PXXXXX-MAIN01 "Main Unit" will be 8473.30.5000, Harmonized Tariff Schedule of the United States (HTS), which provides for other parts and accessories of the machines of heading 8471. The rate of duty will be free.

The applicable subheading for the model KZ1-XXXCPPUA-CPUBD01 "CPU Daughter Board" will be 8473.30.1000, HTS, which provides for printed circuit assemblies that are parts and accessories of the machines of heading 8471. The rate of duty will be free.

The applicable subheading for the model KZ1-X10CDR-CDROM1 "CD-ROM Module" will be 8471.70.6000, HTS, which provides for other storage units, not assembled in cabinets for placing on a table, desk, wall, floor or similar place. 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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