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NY H89358




April 3, 2002

CLA-2-84:RR:NC:1:110 H89358

CATEGORY: CLASSIFICATION

TARIFF NO.: 8471.80.1000; 8473.30.5000

Ms. Jennifer Churchill
Hitachi Computer Products (America) Inc.
1800 E. Imhoff
Norman, OK 73071

RE: The tariff classification of Hitachi’s RAID450 Array Storage Subsystem components from Japan and hard disk drive canisters from the Philippines.

Dear Ms. Churchill:

In your letter dated February 26, 2002, on behalf of Hitachi Computer Products (America) Inc. (“HICAM”) you requested a tariff classification ruling.

The merchandise under consideration is the RAID450 Array Storage Subsystem components. The RAID450 is the next generation of Hitachi’s array storage subsystem, which uses an enhanced redundant array of independent disk design that allows for continuous storage, backup and maintenance of the subsystem without having to take the system down. The RAID450 subsystem consists of a controller (“DKC”) and up to four disk storage units (“DKU”). The components in the RAID450 are the DKC-460I-5 Disk Controller Frame, DKU455I-18 Disk Array Frame, DKU-F455I72J1/4 Hard Disk Drive Canisters, DKC-F460I-8HSE Fiber 8-port Adapter for Short Wavelength and the DKC-F460I-8ML Mainframe Fiber 8-port Adapter for Long Wavelength.

The DKC-460I-5 is the Disk Controller Frame that performs as an interface between the subsystem’s DKU storage units and the central processing unit (CPU). The DKC460I-5 Disk Controller Frame is the disk subsystem’s basic unit and consists of channel adapters, disk adapters, cache memory, power supplies, a control panel, etc. The DKC460I-5 Disk Controller is a single cabinet measuring approximately 30.8 inches wide by 31.5 inches deep and is 73.2 inches high. The control unit is equipped with an SVP (laptop PC), which is used to service the subsystem, monitor its running condition, and analyze faults.

The DKU455I-18 Disk Array Frame is a single cabinet that connects to the Disk Controller Frame. The Disk Array Frame is equipped with its own power supplies and cooling fans. This model can be equip with up to eight HDU boxes which can hold up to 32 Hard Disk Drive Canisters (HDD) each. The DKU455I-18 cabinet measures approximately 29.5 inches wide by 31.5 inches deep and is 73.2 inches high. It will be imported without any hard disk drive canisters installed. Noting HQ954361, it does not meet Chapter 84, Note 5(B) with regard to units.

The DKU-F455I72J1/4 Hard Disk Drive Canisters are mounted in the Disk Array Frame. The “4” at the end of the DKU number indicates that there are 4 HDD Canisters. The canisters do not contain the read/write printed circuit assemblies. As per HQ957319 they do not meet the definition of an ADP “unit.” Therefore, classification under heading 8471, HTSUS, is precluded.

The DKC-F460I-8HSE Fiber 8-port Adapter for Short Wavelength and the DKC-F460I-8ML Mainframe Fiber 8-port Adapter for Long Wavelength are Printed Circuit Assemblies (PCAs) that will be mounted into the Disk Controller Frame. The Short and Long Wavelength PCAs are used for data transfer control between the upper host and cache memory, and provides serial and Fiber Client Host Adapter (CHA) for mainframe connection and Fiber CHA for open system connection. Ports are controlled by their respective dedicated microprocessors. Individual ports and disk drives are connected through a Fiber channel (FC-AL Interface).

The applicable subheading for the DKC-460I-5 Disk Controller Frame, DKC-F460I-8HSE Fiber 8-port Adapter for Short Wavelength and the DKC-F460I-8ML Mainframe Fiber 8-port Adapter for Long Wavelength will be 8471.80.1000, Harmonized Tariff Schedule of the United States (HTS), which provides for “Automatic data processing machines and units thereofOther units of automatic data processing machines: Control or adapter units.” The rate of duty will be free.

The applicable subheading for the DKU455I-18 Disk Array Frame imported without the Hard Disk Drive Canisters will be 8473.30.5000, Harmonized Tariff Schedule of the United States (HTS), which provides for “Parts and accessoriessuitable 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 DKU-F455I72J1/4 Hard Disk Drive Canisters imported separately will be 8473.30.5000, Harmonized Tariff Schedule of the United States (HTS), which provides for “Parts and accessoriessuitable 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.

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 646-733-3016.

Sincerely,

Robert B. Swierupski
Director,

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