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NY F89326




August 3, 2000

CLA-2-84:RR:NC:MM:110 F89326

CATEGORY: CLASSIFICATION

TARIFF NO.: 8471.80.1000; 8473.30.5000; 8504.40.7012

Mr. Douglas Turnbull
Hitachi America, Ltd.
50 Prospect Avenue
Terrytown, NY 10591-4698

RE: The tariff classification of the "DKC-410I" and its individual subsystem, disk control unit, power supplies and frame assembly parts for the RAID400. All items will be imported from Japan.

Dear Mr. Turnbull:

In your letter dated June 30, 2000, on behalf of Hitachi America, Ltd., you requested a tariff classification ruling.

The merchandise under consideration involves the complete disk controller unit and power supply units thereof for the RAID400. The RAID400 is the next generation of Hitachi's array storage subsystems. The subsystem consists of a disk storage unit "DKU" and disk control unit "DKC" model DKC-410I. The DKC-401I, in its imported condition is one cabinet in the RAID400. In addition to the complete DKC-401I unit, you request classification of parts, components and subassemblies that make up the DKC-410I. The DKC-410I is the controller unit for the RAID400 Array Storage Subsystem. This subsystem uses an enhanced Redundant Array of Inexpensive Disks ("RAID") design, which allows for continuous storage, backup and maintenance of the subsystem without having to take the system down. The DKC-410I is a controller that performs as an interface between the subsystem's storage unit and the CPU. It is functionally inseparable from the DKU storage unit. The DKC-410I performs only data transfer functions and is an upgrade of the DKC-310I, which was the subject of NY Ruling C83835. The "DKU" disk storage unit is the subject of another ruling request.

In addition to the DKC-410I, you request classification for frame assembly parts, DWG #1501869-H, DWG #1505942-A, DWG #1505943-A and DWG #3245008-C for the DKC. These are sheet metal parts preformed to serve as the side cover, front and rear door of the DKC. Hitachi refers to these parts as "L" parts. You also request classification of three power supplies, DWG #5503485-1, DWG #5503486-1 and DWG #5503487-2. The information supplied with your ruling request show variable power output ratings from a low of 89.1W at 3.3V to a high of 265W at 5V. Hitachi refers to these parts as "M" parts. The parts and subassemblies mentioned in this paragraph are the parts and subassemblies necessary for the subassembly manufacturing and final assembly in the United States.

The applicable subheading for the complete and assembled DKC-410I controller units will be 8471.80.1000, Harmonized Tariff Schedule of the United States (HTS), which provides for "Automatic data processing machines and units thereof; magnetic or optical readers, machines for transcribing data onto data media in coded form and machines for processing such data, not elsewhere specified or included: Other units of automatic data processing machines: Control or adapter units." The rate of duty will be free.

The applicable subheading for the frame assembly, "L" part numbers, DWG #1501869-H, DWG #1505942-A, DWG #1505943-A and DWG #3245008-C will be 8473.30.5000, Harmonized Tariff Schedule of the United States (HTS), which provides for "Parts and accessories (other than covers, carrying cases and the like) suitable for use solely or principally with machines of headings 8469 to 8472: Parts and accessories of the machines of heading 8471: Not incorporating a cathode ray tube: Other." The rate of duty will be free.

The applicable subheading for the three power supplies, "M" part numbers, DWG #5503485-1, DWG #5503486-1 and DWG #5503487-2 will be 8504.40.7012, Harmonized Tariff Schedule of the United States (HTS), which provides for "Electrical transformers, static converters and inductors; parts thereof: Static converters: Power supplies for automatic data processing machines or units thereof of heading 8471: OtherWith a power output exceeding 150 W but not exceeding 500 W." 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 Eileen S. Kaplan at 212-637-7019.

Sincerely,

Robert B. Swierupski
Director,

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