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NY C80075




October 2, 1997

CLA-2-84:RR:NC:1:110 C80075

CATEGORY: CLASSIFICATION

TARIFF NO.: 8473.30.50000; 8473.30.1000; 8471.70.6000

Ms. Machiko Celli
Nippon Express USA, Inc.
P.O. Box 2478
South San Francisco, CA 84083-2487

RE: The tariff classification of notebook computer sub-assemblies from Japan.

Dear Ms. Celli:

In your letter dated September 9, 1997, on behalf of Stotec America, Inc. you requested a tariff classification ruling.

The merchandise under consideration involves sub-assemblies for notebook computers, such as the main unit, CPU daughter board, and an internal CD-ROM module. These sub-assemblies will be imported in various configurations.

The "Main Unit", model number KH1-PXXXXX-MAIN01, consists essentially of electrical circuits, a board, an LCD display, a keyboard, a battery pack, an AC Adapter, and a Floppy disc drive. The main board does not contain a CPU chip. It has dimensions of 12" in width, 9.56" in depth, and 1.53" in height, and weighs approximately 5.1 pounds. It has 16MB of EDO RAM memory, and a 12.1" DSTN/TFT LCD display. This main unit is imported in a sub-assembly format.

The CPU Daughter board, model number KH1-XXXCPUA-CPUBD01, is a printed circuit board assembly that goes into the notebook computer. It is 90mm x 58mm in dimension, and incorporates a CPU chip (Pentium 166/200/233/266 Mhz) and 256KB of PB-SRAM . It does not incorporate a BIOS chip.

The CD-ROM Module, model KH1-X14CDR-CDROM1, is an internal CD-ROM module that fits into the notebook computer. It incorporates a transfer rate speed of x14, an access time of 190ms or faster, and is encased in a plastic case. It measures 130.7mm x 130.5mm x 13.7mm.

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. Please note also HQ rulings 954411, 957178, and NY Ruling letters B85751 and B86602.

The applicable subheading for the 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 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 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
Director,

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