CLA-2-84:S:N:N1:110 813723
Mr. Kenneth G. Weigel, Esq.
Kirkland & Ellis
655 15th Street, N.W.
Washington, D.C. 20005
RE: The tariff classification of components for model DKC2101
controller units and a laptop computer from Japan.
Dear Mr. Weigel:
In your letter dated August 8, 1995, on behalf of Hitachi
Computer Products (America), Inc., you requested a tariff
classification ruling.
The merchandise under consideration involves complete
controller units; components and subassemblies of the controller
units, and a laptop computer. The controller unit consists of a
complete and assembled model DKC2101. Stage 1 of these shipments
will consist of the complete and assembled DKC2101. In Stage 2,
and Stage 3, the shipments will consist of parts and sub-
assemblies of the DKC unit. All of the "S" parts will be shipped
separately from the "L" and "M", and will be classified
individually in accordance with GRI-1. A laptop computer will
also be imported as an "S" part.
The DKC2101 is the controller unit for Hitachi's 7700 Array
Storage Subsystem. This system uses an enhanced Redundant Array
of Independent Disks ("RAID") design which allows for continuous
storage, backup and maintenance of the subsystem without having
to take the system down. The DKC2101 is a controller which
performs as an interface between the subsystem's storage unit and
the CPU. It is functionally inseparable from the storage unit.
The DKC basically performs only data transfer functions. The
DKC2101 is an upgrade of the DKC901-3 model, which was the
subject of N.Y. Ruling 886517.
The control system for the DKC2101 is different from that in
prior controllers. The hard disk drive and the floppy disk drive
and boards of the DKC901-3 have been replaced with a laptop
computer.
During Stage 1, the DKC2101 will be imported in its complete
and assembled form. In Stage 2 and Stage 3 the parts and
subassemblies necessary for the subassembly manufacturing and
final DKC assembly in the United States will be imported. The
parts and subassemblies will be in imported in large ("L"),
medium ("M") and small ("S") parts groups.
The "L" parts will consist of: 1 - the larger sheet metal
parts of the DKC2101. These parts constitute the DKC's frame.
In Stage 2 and Stage 3 the "L" parts will consist of the frame
assembly, front and rear door assemblies, and the side cover
assembly.
In Stage 2, the "M" parts will consist of the back panel
assembly and the printed circuit board assembly. The printed
circuit board parts are Single In line Memory Modules ("SIMMS")
which are printed circuit boards populated with several DRAMS.
In Stage 3, the "M" parts will consist of only the back panel
assemblies.
The "S" parts in Stage 2 and Stage 3 will consist of the
smaller parts necessary for subassembly and final DKC manufacture
in the United States. The "S" parts will include parts used by
Hitachi to produce the DKC including: the wire harness, printed
circuit board assemblies, the power supply assembly, and the
mechanical service assembly. All of the "S" parts will be
shipped separately from the "L" and the "M" parts, and will be
classified individually in their appropriate HTS provision in
accordance with GRI-1. A laptop computer will be imported as a
"S" part.
The applicable subheading for the complete and assembled
DKC2101 will be 8471.99.1500, Harmonized Tariff Schedule of the
United States (HTS), which provides for other control or adapter
units for use with automatic data processing machines. The rate
of duty will be free.
The applicable subheading for the "L" parts and the "M"
parts which consist of the cabinet, frame, similar sheet metal
parts, and the "M" parts which consist of the back panel assembly
and printed circuit boards or SIMMS will be 8473.30.5000,
Harmonized Tariff Schedule of the United States (HTS), which
provides for parts and accessories of the machines of heading
8471 not incorporating a cathode ray tube. The rate of duty will
be free.
Your inquiry does not give us enough information for us to
give a classification ruling on the laptop computer. Your
request should include descriptive literature of this laptop
computer. Are all the components of this laptop computer in one
common housing? We also need a clarification of your reference
to a monochrome monitor. Is this a separate unit, or is this
monochrome monitor an integral component of the laptop computer?
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
New York Seaport