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NY D81184




August 28, 1998

CLA-2-84:RR:NC:1:110 D81184

CATEGORY: CLASSIFICATION

TARIFF NO.: 8471.80.9000

Mr. Weldon Stanley Jones
Peregrine Technologies & Solutions, Inc.
6116 N. Central Expressway, Suite 920
Dallas, Texas 75206-5155

RE: The tariff classification of a computer adaptor from England.

Dear Mr. Jones:

In your letter dated August 4, 1998, you requested a tariff classification ruling.

The merchandise under consideration involves a model GPS 1000/C Atomic Satellite Clock (ASC) adaptor unit. This ASC adaptor unit is utilized to insert accurate date/time information from a Global Positioning Satellite into a computer operating system. The components of this ASC adaptor unit consist of: 1) an Antenna, 2) a IP65 Booster/Connector Box, 3) an IPC Interface Box, and 4) a Micro-controller/processor. These items will be packaged in a single container weighing 5.7 lbs, but will be repacked in the United States, and additional components added prior to wholesale and retail sale.

The GPS1000/C ASC adapter unit uses an externally mounted antenna which is able to receive the precise time transmitted by the GPS satellites. The signal can be received in any part of the world. The GPS1000/C is equipped with a serial interface and adjusts the time and date of a LAN network or a computer's internal time with the utilization of software.

The components of the GPS1000/C ASC adaptor unit perform the function of inserting date/time information from the GPS system into a computer or LAN network. The GPS antenna detects and receives the signals from a number of GPS satellites. This signal is passed from the antenna to the IP65 booster box, which amplifies the signal from the antenna and translates it to RS485-RS422 protocol for transmission to the microprocessor. The microprocessor receives the signal from the IP65 booster box, reads the information and extracts the absolute time from it. Using this information the microprocessor maintains its own internal real time clock, from which its operating system uses the time supplied from the microprocessor. The adapter will connect to a computer by connecting the cable from the microprocessor to a serial port on the computer.

Although the GPS1000/C ASC adapter unit interfaces with an automatic data processing (ADP) computer, it is not principally used with other ADP machines, or groups of input or output units. HQ 955873 dated March 7, 1994, and HQ 954494 dated February 9, 1994 are noted. The GPS1000/C ASC adaptor unit interface effects the interconnection of a central processing unit (CPU) computer or LAN network to Global Positioning Satellites. The GPS1000/C ASC adaptor unit also meets the definition of a "composite good" (Antenna, IP65 Booster/ Connection Box, IPC Interface Box, and Micro-controller/ processor) made up of different components which are described in different provisions of the HTS. Noting GRI-3(b), the components of this "composite good" are interconnected, adapted to each other, and mutually complementary. The "essential character" of this composite good would be exemplified by the micro-controller/processor unit.

The applicable subheading for the GPS1000/C ASC adaptor unit will be 8471.80.9000, Harmonized Tariff Schedule of the United States (HTS), which provides for other units of automatic data processing 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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