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NY D83254




October 14, 1998

CLA-2-84:RR:NC:1:110 D83254

CATEGORY: CLASSIFICATION

TARIFF NO.: 8471.90.0000

Mr. Lee Silberzahn
Sony Electronics Inc.
123 Tice Boulevard
Woodcliff Lake, New Jersey 07675

RE: The tariff classification of a CD Duplicator from Japan.

Dear Mr. Silberzahn:

In your letter dated October 7, 1998, you requested a tariff classification ruling.

The merchandise under consideration involves a "Sony" model SDS-C400 compact disc (CD) Duplicator. This device functions as a "copy machine" CD duplicator that can simultaneously duplicate up to six CD's from one pre-recorded CD. The unit measures approximately 21.5 inches in length by 8.7 inches in width, and has a depth of 23.4 inches.

The SDS-C400 CD duplicator consists of one CD-ROM drive as the source drive and six CD recordable drives as the destination drives. It is capable of duplicating audio, video and multimedia discs for PC applications. In order to operate the duplicator, a recorded disc is placed in the CD-ROM drive and one blank disc is placed in each of the six recordable drives. With the push of a button, the duplicator automatically copies the information from the source drive to the target drives via a direct read/write process from the source to target. The data is not stored temporarily by the duplicator during the duplication process.

The model SDS-C400 CD duplicator can be used by businesses to reproduce internally developed and recorded material. This technology provides confidentiality for sensitive information that needs to be kept "in house" without the use of outside firms. Consideration under 8521.90 would be precluded since this apparatus is not solely designed to reproduce images and sound directly on a television receiver.

The applicable subheading for the "Sony" model SDS-C400 CD Duplicator will be 8471.90.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for other machines for transcribing data onto data media in coded form and machines for processing such data, not elsewhere specified or included. 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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