CLA-2-84:S:N:N:110 896031

Ms. Susan Kohn Ross
Ross & Associates
5777 West Century Blvd.
Suite 520
Los Angeles, CA 90045-5659

RE: The tariff classification of LCD Desktop Projectors from Japan and Mexico.

Dear Ms. Ross:

In your letter dated February 3, 1994, on behalf of Proxima Corporation, you requested a tariff classification ruling. The merchandise under consideration involves two models of LCD Desktop Projectors that are designed for displaying computer data onto a screen or wall. The models under consideration are Desktop Projectors 2300 and 2700, both of which are self-contained personal computer peripherals for projecting color computer images onto a large screen or wall.

The 2300 includes broad computer compatibility with IBM and Macintosh computers and interactive remote control of software. It is also compatible with Proxima's unique Cyclops interactive pointer system- a cordless mouse for computer-based meetings and presentations. This unit incorporates a Super Twisted Nematic (passive) LCD panel, that has a 640 x 480 pixel resolution. It does not have the ability to hook up to video components such as VCR's and video cameras. The unit is approximately 13.1 inches in width, 5.9 inches in height, and 17 inches in length. The projection portion of this unit incorporates 2 Tungsten Halogen Quartz lamps, and can create a brightness of 45 ANSI lumens. The lift-up mirror allows easy placement of the image on the screen, and the lift-up cover protects the projector mirror and lens when closed for transport or storage. This model and the 2700 are directly connectable to a computer.

The 2700 also is compatible with most computers and the Cyclops interactive pointer system. It incorporates an active- matrix LCD flat panel that projects crisp color images onto the screen, at a resolution of 640 x 480 pixels. With the addition of an optional video card upgrade adapter, this unit has the ability to hook up with video components such as VCR's and video cameras. The dimensions of this unit are the same as the 2300 model, with both models weighing about 18 pounds. The internal projection components of this model are similar to the 2300 model. The visual diagonal of the internally mounted LCD panel for both models is 8.4 inches.

Both of these models are designed and principally used for projecting computer images onto a screen, and both would meet the definition of a "unit" of an ADP system as per Legal Note 5 (B) to Chapter 84 of the HTS. The applicable subheading for the Model 2300 and 2700 Desktop Projectors will be 8471.92.3000, Harmonized Tariff Schedule of the United States (HTS), which provides for Display units, without cathode-ray tube (CRT), having a visual display diagonal not exceeding 30.5 cm. The duty rate will be free.

The question of classification for the Models 2800 and 8300, which are multimedia desktop projectors, is being referred to the Office of Regulations and Rulings, U.S. Customs Service Headquarters, 1301 Constitution Avenue, N.W., Washington D.C. 20229. A ruling will be issued to you from that office.

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