CLA-2-84:S:N:N1:110 814235
Mr. D. Taylor Pillsbury
Glad & Ferguson
One Sutter Street, 10th Floor
San Francisco, California 94104
RE: The tariff classification of an adapter unit from China.
Dear Mr. Pillsbury:
In your letter dated August 29, 1995, on behalf of Enhance
Cable Technology., you requested a tariff classification ruling.
The merchandise under consideration involves an "Enhance"
adapter device which is designed for use with a computer in order
to allow the user external access and control of the audio
output. Each unit consists of a small plastic "box" which
measures approximately 1 3/4 inch by 2 5/8 inch by 5/8 inch,
which contains a printed circuit board. On the face of the box
are two stereo mini jacks and a volume control knob. Another
stereo jack is located on the back of the box. A two foot cable
connects from the box to a stereo jack which is designed to
attach to a sound card or a mini jack located in or on a central
processing unit (CPU). Speakers may be attached to the box or
headphones.
The "Enhance" adapter device appear to meet the definition
of a unit of an automatic data processing (ADP) system, since
this adapter is connectable to the central processing unit (CPU)
either directly or through one or more units. This device is
designed to perform the principal function of effectuating
interconnection of the CPU to speakers and/or headphones. Since
the speakers and/or headphones are non ADP units, and this device
is comparable to a signal converting unit as described in the
Explanatory Notes to the HTS on page 1300, consideration under
8471.99.1500 would be precluded. Please note Headquarters'
Rulings 955873 and 956208 for similar merchandise.
The applicable subheading for the "Enhance" ADP adapter unit
will be 8471.99.9000, Harmonized Tariff Schedule of the United
States (HTS), which provides for other, other units for use with
automatic data processing machines. The rate of duty will be 3
percent ad valorem.
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