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NY N005267




February 6, 2007

CLA-2-84:RR:E:NC:1:120

CATEGORY: CLASSIFICATION

TARIFF NO.: 8471.70.4065, 8471.80.1000, 8471.80.9000, 8473.30.1140, 8473.30.5100

Ms. Jennifer Churchill
Hitachi Computer Products (America), Inc. 1800 E. Imhoff Road
Norman, OK 73071-1202

RE: The tariff classification of Hitachi’s RAID600 Array Storage Subsystem components from Japan and hard disk drive canisters from the Philippines

Dear Ms. Churchill:

In your letter dated January 10, 2007 you requested a tariff classification ruling on behalf of Hitachi Computer Products (America), Incorporated (HICAM).

The merchandise under consideration is the RAID600 Array Storage Subsystem components. The RAID600 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 RAID600 subsystem consists of up to four (4) disk storage units (DKU) and a disk control unit (DKC). The components in the RAID600 are the DKC610I-5 Disk Controller Frame without doors, DKC-F605I-18 Disk Array Frame without doors, DKC-F605I-300JS 1 Hard Disk Drive Canister, DKC-F6051-AKT DKU Expansion Kit, and a DKC-F610I-SVP SVP High Reliability Support Kit.

The DKC610I-5 is the Disk Controller Frame that performs as an interface between the subsystem’s DKU storage units and the central processing unit (CPU). It is a single cabinet that measures 75.59“ high x 36.42” deep x 30.79” wide. It is the disk subsystem’s basic unit equipped with an SVP (service processor), channel adapter, dish adapter, cache memory, shared memory, a CSW (data path expansive kit), HDU boxes in which disk drives are installed, and power supplies and battery components that supply power to the components installed. The SVP is a CPU box used to service and monitor the subsystem. It is not imported with a keyboard, monitor, or disk drives, and it is not freely programmable. The DKU can hold up to 128 disk drives, and can be connected up to (4) of the DKU–F605I-18 Disk Array Frames.

The DKU–F605I-18 is the Disk Array Frame that connects to the Disk Controller Frame. The Disk Array Frame is a single cabinet that measures 75.59” high x 36.42” deep x 30.79” wide. The cabinet is equipped with its own power supplies, cooling fans and battery boxes. It has four (4) HDU boxes in which each box holds 64 disk drive canisters for a total of 256 disk drives that can be installed. However, it will be imported without any hard disk drive (HDD) canisters installed. Noting HQ954361, it does not meet Chapter 84, Note 5(B) with regard to units. This item is not imported with HDDs installed, and therefore, is precluded from heading 8471.

The DKC-F605I-300JS is a fully assembled HDD canister that is imported separately from the Philippines. It has one canister that contains a 3.5 inch 300GB HDD with a disk drive interface connector and a handle that allows for easy removal of the drive. The HDD contains read/write printed circuit assemblies and is designed for installation in the HDU box of the Disk Array Frame or Disk Control Frame. The HDD meets Chapter 84, Note 5 (B) requirements for ADP “units” since they are connectable to the CPU through the interface and they accept and deliver data in a form that can be used by the system.

The DKC-F605I-AKT is a DKU Expansion Kit that consists of power supplies and (8) populated printed circuit boards used to support additional HDDs in the upper boxes of the Disk Array Frame. It is used to extend the storage capacity.

The SVP High Reliability Support Kit is a back up service processor for the processor mounted onto the controller. It has a Celeron M 1.5GHz CPU, 1GB internal memory, 160GB 3.5” HDD, and (2) local area network (LAN) connectors. It is imported without a keyboard, monitor, modem card, CD-ROM or floppy disk drive. It has a Windows XP Professional operating system, yet it is not freely programmable based on our conference call dated January 24, 2007. You also stated in our conference call that it is an auxiliary device that hooks up to an ADP laptop or desktop PC in order to do maintenance on the ADP machine. The SVP meets Chapter 84, Note 5 (B) requirements for ADP “units” since it is connectable to the CPU and it accepts and delivers data in a form that can be used by the system.

The applicable subheading for the DKC610I-5 Disk Controller Frame will be 8471.80.1000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "Automatic data processing machines and units thereofOther units of automatic data processing machines: Control or adapter units." The general rate of duty will be free.

The applicable subheading for the DKU–F605I-18 Disk Array Frame will be 8473.30.5100, Harmonized Tariff Schedule of the United States (HTSUS), 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 general rate of duty will be free.

The applicable subheading for the DKC-F605I-300JS HDD Canister will be 8471.70.4065, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "Automatic data processing machines and units thereofStorage units: Magnetic disk drive units: Other: Not assembled in cabinets, and without attached external power supply: Hard magnetic disk drive units." The general rate of duty will be free.

The applicable subheading for the DKC-F605I-AKT DKU Expansion Kit will be 8473.30.1140, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "Partssuitable 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: Printed circuit assemblies: Memory modules suitable for use solely or principally with machines of heading 8471." The general rate of duty will be free.

The applicable subheading for the SVP High Reliability Support Kit will be 8471.80.9000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "Automatic data processing machines and units thereofOther units of automatic data processing machines: Other: Other." The general rate of duty will be free.

Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.

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 Denise Faingar at 646-733-3010.

Sincerely,

Robert B. Swierupski
Director,

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