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NY D81614




August 31, 1998

CLA-2-84:RR:NC:1:110 D81614

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 14, 1998, you requested a tariff classification ruling.

The merchandise under consideration involves a computer adaptor. This adaptor unit is utilized to insert accurate date/time information from a Global Positioning Satellite into a computer operating system. The components of this computer adaptor consist of two parts: 1) the clock body (containing the antenna, radio/microprocessor module, clock module, LCD display and computer interface (module), and 2) the serial connector cable. These items will be packaged in a single container weighing 16.2 ounces, but will be repacked in the United States, and additional components added prior to wholesale and retail sale.

The antenna of the clock module detects the signals from a transmitter broadcasting an accurate time signal. The signal detected by the antenna is received by the radio microprocessor, which amplifies it and converts it into signals suitable for use by the clock module. The clock module uses the signal from the microprocessor to check and if necessary adjust the time provided by a quartz clock. This time is passed to the computer interface module and to an LCD display. The computer interface module converts the signal provided by the clock module into RS-232 data format for transmittal to the computer via the serial connector. Signals from the radio controlled clock are received by the computer by a serial cable connected to a Comm. Port. They are then processed using specialized software which ensures the correct day, date and time information is constantly provided to a file on the computer network which can be read by all machines on the network. This series of Atomic Radio Controlled (ARC) Time clocks receive the time signal from a station, and uses the time to synchronize a network or single computer to the aboslute correct time. The ARC Time clocks interface to a computer via a serial port and driver software available for NOVELL, Windows NT, and other software.

Although the instant computer adaptor 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. This adaptor unit interface effects the interconnection of a central processing unit (CPU) computer or LAN network to Global Positioning Satellites. This computer adaptor unit also meets the definition of a "composite good" (the clock body consisting of the antenna, radio/microprocessor module, clock module, LCD display and computer interface module) and the serial connector cable) 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 inter- connected, adapted to each other, and mutually complementary. The "essential character" of this composite good would be exemplified by the computer interface module.

The applicable subheading for the instant 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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