CLA-2-84:S:N:N1:110 872117
Mr. Dennis Heck
Castelazo & Associates
5420 West 104th Street
Los Angeles, CA 90045
RE: The tariff classification of a notebook computer and
software from Singapore.
Dear Mr. Heck:
In your letter dated March 4, 1992, on behalf of Epson
America Inc., you requested a tariff classification ruling.
The merchandise under consideration involves three models of
notebook computers that incorporate a 80386 microprocessor, 2MB
of RAM, an internal 3.5 inch 1.44MB floppy disk drive, an
integrated keyboard, and a LCD flat panel display. The computer
is imported and marketed with a nylon carrying case, and also
includes a detachable power cord, two Ni-Cad batteries, one
AC/DC adapter, and one software diskette. Epson notebook
computer model EO400 is the NB-SL/20 monochrome LCD 20 MHZ
version. Model EO401 is the NB-SL/25 monochrome LCD 25 MHZ
version. Model EO402 is the NB-SL/25C active matrix color LCD 25
MHZ version. The unit, with one hard disk drive and one battery
weighs 6.5 pounds. The keyboard, flat panel display and
processor portion are in one common housing.
The nylon carrying case is padded on the inside with two MM
polyethylene foam, and includes inside pockets of PVC for holding
several software diskettes and thin manuals. The case also has a
sturdy carrying handle and a zippered closure on three sides.
This case is specially fitted to contain the notebook computer,
and is suitable for long-term use. It thus appears to meet the
GRI-5 (a) provision and would thus be classified at the same rate
as the computer.
The applicable subheading for the three models of notebook
computers will be 8471.20.0090, Harmonized Tariff Schedule of the
United States (HTS), which provides for digital automatic data
processing machines, containing in the same housing at least a
central processing unit and an input and output unit, whether or
not combined. The duty rate will be 3.9 percent ad valorem.
Noting Legal Note 6 to Chapter 85 of HTS, the software disk
included in the computer case is classified separately.
The applicable subheading for the user disk software package
will be 8524.90.4080, HTS, which provides for other recorded
media. The rate of duty will be 9.7 cents per square meter of
recording surface.
Your inquiry does not provide enough information for us to
give a classification ruling on the color active matrix LCD
display unit that is separately imported. Your request for a
classification ruling should include descriptive literature on
this flat panel display unit, and specifics as to whether this
display unit is capable of use with other computers or merely
designed for use with the three models of Epson computers.
Please clarify also the country of origin for these display
units, and whether or not these display panels were assembled in
Singapore of Japanese components.
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