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May 13, 1999

CLA-2-90:RR:NC:1:110 E81596

CATEGORY: CLASSIFICATION

TARIFF NO.: 9009.30.0000

Mr. John McManus
Itochu International Inc.
335 Madison Avenue
New York, N.Y. 10017

RE: The tariff classification of Panaboards from Japan.

Dear Mr. McManus:

In your letter dated May 7, 1999, you requested a tariff classification ruling.

The merchandise under consideration involves three models of "Panasonic Panaboards" (UB-1880, UB-1280, and UB-900) which are designed to be used in a business office. Similar to a blackboard, the Panaboard is a "whiteboard", a reversible steel board coated with a white plastic. Erasable color markers are used to sketch flow charts, graphs, and other items that can be seen by a large audience due to the size of the writing surface. The UB-1880 measures approximately 3 feet by 5 1/2 feet, the UB-1280 approximately 3 feet by 4 feet, and the UB-900 approximately 2 feet by 3 feet.

An integral optical scanning device allows copies to be made of any markings made on the board. The Panaboard is designed for use at business meetings and lectures, and its copying capability allows for the distribution of projects and any ideas that are conceived at such functions. These Panaboards do not have the capacity to be networked with personal computers (PCs) since the "PC Interface Kit" will not be imported with these Panaboards.

The UB-1880, UB-1280, and UB-900 Panaboards meet the definition of a "composite good", (copier, scanner, and writing board) whose "essential character is exemplified by its copy function. In their condition as imported, these Panaboards cannot perform a printing or networking function since they lack the interface capacity provided by the PC Interface Kits. Would thus distinguish the subject merchandise from the Panaboards and interface kits noted in NY Ruling Letter D85371.

The applicable subheading for the UB-1880, UB-1280, and UB-900 "Panasonic Panaboards" imported without the "PC Interface Kit" will be 9009.30.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for thermocopying photocopying apparatus. The rate of duty will be 1.8 percent ad valorem.

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 212-637-7019.

Sincerely,

Robert B. Swierupski
Director,

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