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NY C83477




January 22, 1998

CLA-2-84:RR:NC:1:110 C83477

CATEGORY: CLASSIFICATION

TARIFF NO.: 8471.80.1000

Mr. Jeffrey W. Tooze
Geo. S. Bush & Co., Inc.
877 West Main Street, Suite 505
Boise, Idaho 83702

RE: The tariff classification of a Universal Serial Bus Smart Cable from Taiwan.

Dear Mr. Tooze:

In your letter dated January 13, 1998, on behalf of In-System Design, Inc., you requested a tariff classification ruling.

The merchandise under consideration is a device which is known as "Universal Serial Bus (USB) Smart Cable". By utilizing hardware and software, the "USB Smart Cable" provides intelligent and transparent protocol conversion between the USB on the personal computer (PC) side and IEEE 1284 parallel on the printer side. It will allow any "Windows" PC with a USB port to print nearly any parallel printer.

The "USB Smart Cable" is constructed of a USB series A connector, a USB compliant two meter 5 conductor insulated and shielded cable, and an IEEE 1284-B connector attached to a printed circuit board installed inside the IEEE 1284 connector housing. The heart of the device is the USS-720 Instant USB integrated circuit. This device is compatible with USB hub devices and virtually all parallel printer devices.

The "USB Smart Cable" meets the definition of a "unit" of an automatic data processing (ADP) machine as noted in Legal Note 5 (B) of Chapter 84 to the HTS. Consideration was given to classification under heading 8544, HTS, which provides for insulated electric conductors. The presence of the USS-720 chip however, goes beyond what is provided for in Explanatory Note 85.44. The "USB Smart Cable" is indirectly connectable to the central processing unit (CPU), and is able to accept and deliver data. It also appears to have the principal function of inter- connecting a CPU unit to other units of ADP machines, thereby providing "control" and "adaption" functions. Please note HQ 953921, HQ 957325, and NY A81236 for rulings involving similar merchandise.

The applicable subheading for the "USB Smart Cable" device will be 8471.80.1000, Harmonized Tariff Schedule of the United States (HTS), which provides for control and adapter units for ADP 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
Director,

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