CLA-2-84:RR:NC:MA:110 A 87832
Mr. Robert K. Curlee
RKC Consultants, Inc.
3806 68th Street
Lubbock, Texas 79413
RE: The tariff classification of a silicone elastomer keypad
from Hong Kong
Dear Mr. Curlee:
In your letter dated September 17, 1996, you requested a
tariff classification ruling.
The merchandise under consideration involves a silicone
elastomer keypad that is designed for use with a "Shoppers
Calculator".
This keypad consists essentially of 18 silicone elastomer
keys attached to a silicone elastomer frame. It is approximately
3 « inches in length, and 2 « inches in width. It is flexible,
and the 18 keytops are marked with alpha-numeric lettering. They
do not however incorporate any interface electronics, nor do they
contain "carbon pills" on the back side of the device. When
added to a plastic top case, calculator assembly, plastic bottom
case, and screws, a complete calculator will be created.
Noting Legal Note 2 (a) to Section 16 of the HTS, no
specific provision appears to exist for this device, in its
imported state. Since this device is specifically designed for a
calculator, and appears to be principally used with calculators,
it would be classifiable as a component part of the calculator.
The applicable subheading for the silicone elastomer keypad
will be 8473.21.0000, Harmonized Tariff Schedule of the United
States (HTS), which provides for parts and accessories of the
machines of 8470 for electronic calculator machines of subheading
8470.10, 8470.21, or 8470.29. The rate of duty will be 3.1
percent ad valorem.
This ruling is being issued under the provisions of Part 177
of the Customs Regulations (19 C.F.R. 177).
A copy of the ruling or the control number indicated above
should be provided with the entry documents filed at the time
this merchandise is imported. If you have any questions
regarding the ruling, contact National Import Specialist Art
Brodbeck at 212-466-5490.
Sincerely,
Roger J. Silvestri
Director
National Commodity
Specialist Division