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NY F85701




April 25, 2000

CLA-2-90:RR:NC:MM:114 F85701

CATEGORY: CLASSIFICATION

TARIFF NO.: 9013.80.7000

Mr. Kenneth G. Weigel
Kirkland & Ellis
655 Fifteenth Street, N.W.
Washington, D.C. 20005

RE: The tariff classification of liquid crystal display picture frames for displaying digital photographs

Dear Mr. Weigel:

In your letter dated April 3, 2000 you requested a tariff classification ruling on behalf of Kensington Technology Group.

The PictureFrame by Kensington, as the product is presently known, is a liquid crystal display (LCD) picture frame which displays a sequence of downloaded digital photographs. One of the versions will have a 7.2-inch LCD screen with VGA resolution (640 by 480 pixels). It will be encased in a decorative wooden frame. The second version under development is a 5.4-inch LCD screen with quarter VGA resolution (320 by 240 pixels). It will be encased in a decorative silver frame.

At the time of importation, the LCD picture frames will contain the printed circuit board, the row and column drivers and a flash memory data storage device capable of holding digital photographic images. A cable will connect the LCD picture frames to a computer’s CPU through a USB connection. The 7.2-inch VGA version will be capable of holding 24 digital photographic images. The 5.4-inch version will be capable of holding 12 digital photographic images.

The PictureFrame must be connected to a computer’s CPU in order to download the digital photographs into the flash memory storage device. The PictureFrame is then able to display the images either by automatically cycling through the 24 or 12 photographs (in the play mode), or by manual selection of individual photographs.

The LCD picture frames are not classifiable in heading 8471, Harmonized Tariff Schedule of the United States (HTS), because they are not designed to function as a unit of an automatic data processing (ADP) system. While they do interface with a computer for the purpose of downloading digital photographs, they are designed as stand alone photographic display frames. As such, they are not principally used in an ADP system, nor can they be compared to computer monitors which are designed as ADP output devices.

The applicable subheading for the wooden LCD picture frame with VGA resolution and the silver LCD picture frame with quarter VGA resolution will be 9013.80.7000, Harmonized Tariff Schedule of the United States (HTS), which provides for liquid crystal devices not constituting articles provided for more specifically in other headings; flat panel displays other than for articles of heading 8528. 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 Barbara Kiefer at 212-637-7058.

Sincerely,

Robert B. Swierupski
Director,

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