NY 858126
Nov 23 1990
CLA-2-84:S:N:N1:110 858126
Mr. Terry Moran
Hitachi Transport System (America), Ltd.
1800 W. 220th Street
Torrance, CA 90501
RE: The tariff classification of a model DKC 801-2 Disk Cache
Controller from Japan.
Dear Mr. Moran:
In your letter dated November 7, 1990, on behalf of Hitachi
Transport System, you requested a tariff classification ruling.
The merchandise under consideration consists of model DKC
801-2 controller which is a control unit that connects the
central processing unit to the external magnetic disk subsystem.
The principal function of the controller is to receive
instructions from the CPU and control the data transferred to and
from the disk storage units. A magnetic disk subsystem consists
of a control unit or DKC, and various varieties of storage
devices known as a DKU. The DKC basically performs only data
transfer functions, and is substantially identical to its
predecessor, the DKC 801-1.
All parts and components imported for the production of the DKC
801-2 controller are separated into one of three groups; "L" (Large),
"M" (Medium), and "S" (Small). The "L" group are basically large frame
and cabinet assemblies. The "M" group consists of specialized
components such as 8 inch floppy disk drives and platter assemblies.
The "S" group is for the most part comprised of smaller components for
making the subassemblies, such as boards, resistors, and integrated
circuits. The three groups of parts and components will be imported
together, and represent essentially all of the necessary parts for the
assembly of the DKC 801-2. Noting GRI 2 (a) to the HTSUS, these
shipments constitute an unassembled and unfinished control unit in its
imported condition. Since almost all of the components are present at
time of importation, the shipment has the essential character of a
finished controller.
The applicable subheading for the unassembled DKC 801-2
disk control unit 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.
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