NY 851540

APR 23 1990


CLA-2-84:S:N:N1:110 851540

Mr. Frederick L. Ikenson, P.C.
1621 New Hampshire Avenue, N.W.
Washington, D.C. 20009

RE: The tariff classification of mother and daughter boards for computers from Mexico.

Dear Mr. Ikenson:

In your letter dated April 16, 1990, on behalf of Zenith Electronics Corporation, you requested a tariff classification ruling.

The merchandise under consideration involves two boards that are designed and used with a desk-top digital processing machine. The boards consist of (1) a "mother board" and (2) a "daughter board", each of which will be separately imported. The mother board performs such functions as keyboard interface for the system; internal memory control; disk drive interface and control for the system; serial/parallel port control for the system; and video control and interface for the cathode ray tube. The board uses socketed ROM devices and includes video RAM devices. The board does not include a central processing unit.

The daughter board, which Zenith calls "Paddle Card" and which is also used as a component in the same desk-top computer, does contain a CPU, but contains no ROM BIOS or RAM devices. For either of the two boards (mother board and daughter board) to function as a digital processing unit, they must be interfaced with each other. Since these two boards are imported separately and neither of the boards meets the definition of a digital processing unit, classification as parts of automatic data processing machines would be appropriate.

The applicable subheading for the mother and daughter boards when imported separately will be 8473.30.4000, 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.

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