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NY K86442




June 18, 2004
CLA-2-84:RR:NC:1:110 K86442

CATEGORY: CLASSIFICATION

TARIFF NO.: 8471.80.9000

Mr. Carlos R. Ruiz
Maquilogistics, Inc.
5575 F.M. 802 Ste. B
Brownsville, TX 78521

RE: The tariff classification of a computer interface from Mexico.

Dear Mr. Ruiz:

In your letter dated May 26, 2004, on behalf of your client Universal Lighting Technologies, Inc. you requested a tariff classification ruling.

The merchandise under consideration is the Universal Lighting Technologies Computer Interface Station Model ES-WB-RS232-UNV-DIM-D. A sample of this device was submitted with your ruling request. This device is designed to be installed into a wall box/outlet similar to a decorator style electrical receptacle and faceplate. It consists of a plastic housing with two printed circuit boards (PCBs) with only a RS-232 serial port nine pin receptacle visible when installed. There are five wires protruding from the back of the device for connecting to line current (Black/Line, White/Neutral and Green/Ground) and two colored control wires. The line power provides the power to the PCBs for the interface circuitry. The RS-232 serial port connector provides a means for connecting a computer into building electrical lighting systems allowing direct control of light levels for dimming purposes via separately available software that must be loaded onto the computer. This device does not perform as a dimmer switch or disconnect per say, it is a device that translates data from a computer in ASCI (American Standard Code for Information Interchange) format into a proprietary protocol Digital Address Command understood by Universal Lighting Technologies AddressPro Ballast.

In your letter you suggest classification under heading 8536 as electrical apparatus for connections to or in electrical circuits or subheading 8543.89 for electrical machines and apparatus, having individual functions not specified or included elsewhere. After reviewing the literature and additional information you provided by phone on June 4, 2004, we believe that this device function as a signal-converting device. The Computer Interface Station also meets the definition of a “unit” of an ADP system, as per Legal note 5(B) to Chapter 84 of the Harmonized Tariff Schedule of the United States, therefore, heading 8471 would be more specific for this product.

The applicable subheading for the Computer Interface Station Model ES-WB-RS232-UNV-DIM-D will be 8471.80.9000, Harmonized Tariff Schedule of the United States (HTS), which provides for “Automatic data processing machines and units thereofmachines for transcribing datamachines for processing such data, not elsewhere specified or included: Other units of automatic data processing machines: Other: Other.” The general 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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