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NY 801545





September 1, 1994

CLA-2-84:S:N:N1:110 801545

CATEGORY: CLASSIFICATION

TARIFF NO.: 8473.30.1000

Mr. Christopher E. Pey
Barnes, Richardson & Colburn
475 Park Avenue South
New York, N.Y. 10016

RE: The tariff classification of a PCMCIA SRAM memory card from Japan

Dear Mr. Rey:

In your letter dated August 23, 1994, on behalf of Mitsui & Co., you requested a tariff classification ruling.

The merchandise under consideration involves an IC memory card (SRAM) that will conform to the PCMCIA (Personal Computer Memory Card Industry Association) standard. The memory cards are portable memory media and will be used to supplement the memory of personal computing devices such as desktop computers, laptops, palmtops and pen-based computers.

This credit card-sized card contains integrated circuits which provide a variety of types of data memory such as SRAM. The sample submitted with this ruling request incorporates SRAM and has either a PCMCIA or 32-pin edge connector along the edge of the card that is inserted into the computing device with which the card is intended to be used. It also incorporates a write-protect switch to prevent inadvertent erasure/overwriting of existing data. It also incorporates a backup battery and includes a battery case lock mechanism.

The SRAM memory card contains multiple number of IC’s such as 256Kbit TSOP x 2 = 64K byte, 1M bit TSOP x 2 = 256K byte, attribute memory IC’s and other IC’s for ASIC and power control. The principle use of these SRAM memory cards appears to be with ADP computing machines.

The applicable subheading for the PCMCIA SRAM memory card will be 8473.30.1000, Harmonized Tariff Schedule of the United States (HTS), which provides for parts and accessories of the machines of heading 8471; printed circuit assemblies, other than for power supplies for automatic data processing machines. The rate of duty will be free.

This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177).

A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction.

Sincerely,

Jean F. Maguire
Area Director,

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