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NY B88350





August 13, 1997

CLA-2-84:RR:NC:1:110 B88350

CATEGORY: CLASSIFICATION

TARIFF NO.: 8473.30.5000

Mr. Dennis Heck
Yamaha Corporation of America
6600 Orangethorpe Avenue
P.O. Box 6600
Buena Park, CA 90622-6600

RE: The tariff classification of an optical head pickup assembly for a Yamaha Expert CDR400 CD player/recorder from Japan.

Dear Mr. Heck:

In your letter dated August 4, 1997, you requested a tariff classification ruling.

The merchandise under consideration involves an optical head pickup assembly that is designed for use with the CDR400 series of CD recorder/players. The CDR series of recorder/players are either internal or external devices designed for computer storage applications. The Yamaha CDR400 series are four speed write and six speed read capability devices, and are Windows 95 plug and play connectable, with either SCSI or EIDE interfaces.

The optical head pickup assembly is a custom designed pickup unit that incorporates such components as mounting tabs, printed circuit boards, optical heads, and ribbon cables with connectors. The complete CDR 400 recorder/reader would in our opinion meet the definition of a "unit" of an ADP system, noting Legal Note 5 (B) to Chapter 84 of the HTS. The optical head pickup assembly would meet the definition of a part of the ADP unit, and appears to be principally used with such units. Application of Legal Note 2 (b) to Section 16 of the HTS, would thus be applicable.

The applicable subheading for the optical head pickup assembly 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.

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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