CLA-2-84:S:N1:110 884639

Mr. Neil B. MacNicol
P.S. Clearance Co. Inc.
8915 S. La Cienega Blvd.
Inglewood, California 90301

RE: The tariff classification of a numeric keypad from Japan

Dear Mr. MacNicol:

In your letter dated April 2, 1993, on behalf of Toshiba America Info Systems, you requested a tariff classification ruling. The merchandise under consideration involves a model #PA7354E numeric keypad that is designed for use as an input unit for such laptop computers as the Toshiba T1000 and T1200. This free-standing device incorporates 10 numeric keys and seven function keys, and is primarily used for the fast and accurate entry of numeric data. When the plug of the keypad is connected to the computer, the computer's main keyboard becomes compatible with an IBM PC enhanced keyboard.

Applications that require large numeric data input such as spreadsheets, database management, and word processing, are ideally suited for this data input device. The numeric keypad is approximately four inches wide, and six inches long, and is a digital device that complies with Part 15 of the FCC Rules. Noting Legal Note 5 (B) to Chapter 84 of HTS, this device meets the definition of a "unit" of an ADP system.

The applicable subheading for the numeric keypad will be 8471.92.9080, Harmonized Tariff Schedule of the United States (HTS), which provides for other input units, whether or not entered with the rest of a system and whether or not containing storage units in the same housing. The rate of duty will be 3.7 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