CLA-2-84:S:N:N1:110 886517
Mr. Kenneth G. Weigel
Washington Square, Suite 1100
1050 Connecticut Avenue N.W.
Washington, D.C. 20036-5304
RE: The tariff classification of a model DKC 901-3 Disk
Controller, and various components thereof, from Japan.
Dear Mr. Weigel:
In your letter dated April 15, 1993, on behalf of Hitachi
Computer Products (America), Inc., you requested a tariff
classification ruling.
The merchandise under consideration consists of a model DKC
901-3 controller, and various components which will constitute this
controller. The DKC 901-3 disk controller 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. The DKC 901-3 controller is
functionally inseparable from the storage unit. It basically
performs only data transfer functions, and is substantially
identical to its predecessor, the DKC 801.
The DKC 901-3 is an upgrade to the DKC 801 model, which was
the subject of Customs Service Ruling 858126. The standard model
will have a larger cache memory capacity than the prior model. The
hard disk drive and the floppy disk drive of the DKC 901-3 have
been reduced from 5.25 inches to 3.25 inches. This shift to
smaller disk drives is the result of general market trends towards
smaller units. The disk drives are not imported in cabinets, nor
are there any external power supplies attached to them.
The first stage of the importations will involve shipments of
complete disk controllers. After the initial complete shipments,
the production of the DKC 901-3 control units will be accomplished
by the importation of some of the parts and subassemblies necessary
for the subassembly manufacture and final DKC assembly in the
United States. These parts and subassemblies will be imported in
large ("L"), medium ("M"), and small ("S") parts groups.
In Stage 2 and 3, the L group of parts will consist of the
rack assembly, front and rear door assemblies, the top and side
cover assemblies, and several large hinges.
In Stage 2, the M parts will consist of the back panel
assemblies, the hard disk drive onto which the operational software
has been copied, and three assemblies which together constitute the
power supply. The power supply assemblies are the following: 1)
the power distribution box; 2) the AC/DC power supply; and 3) DC/DC
power supply cards. In these systems, instead of having all of the
traditional computer power supply functions performed in one
location, there are three assemblies which perform these functions.
The S parts group in Stages 2 and 3 will consist of the
smaller parts necessary for the final manufacture of the DKC 901-
3. In Stage 3, each of the switching power supply assemblies
described above will be imported as S parts. The L, M, and S
parts groups will not be exported from Japan in one shipment. The
S parts will be shipped separately from the L and M parts, and will
be classified in accordance with GRI-1.
The applicable subheading for the complete and assembled DKC
901-3 Disk Controller 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.
The applicable subheading for the L parts which consist of the
cabinet, frame, and similar metal parts and, the M parts which
consist of the back panel assembly 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.
The applicable subheading for the hard disk drive will be
8471.93.3040, Harmonized Tariff Schedule of the United States
(HTS), which provides for hard magnetic disk drive units not
assembled in cabinets, and without attached external power supply.
The rate of duty will be free.
The applicable subheading for the power supply assemblies will
be 8471.99.3200, Harmonized Tariff Schedule of the United States
(HTS), which provides for power supply units suitable for physical
incorporation into automatic data processing machines or units
thereof. 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