CLA-2-84:RR:NC:1:120 M84886

George R. Tuttle
Three Embarcadero Center
Suite 1160
San Francisco, California 94111

RE: The tariff classification of Dragon Series Micro Hard Drives from China

Dear Mr. Tuttle:

In your letter dated June 27, 2006 you requested a tariff classification ruling on behalf of your client, Cornice, Inc.

The Dragon Series Micro Hard Drives (HDD) measure: 1.5 inches x 1.18 inches x 1.3 inches. This hard disk drive is a storage component designed for incorporation in various portable, consumer digital-electronic devices such as USB storage devices, MP3/audio players, digital video recorders and the GPS handheld devices. It can be used in desktop computers equipped with a USB adapter. The rotating magnetic memory media and other electrical and mechanical components in the HDD are encased in a compact, hard metallic housing which enables the digital storage of 8 or 10 gigabytes of data. An active latch mechanism is designed to lock the head of the hard disk drive in place to withstand rugged activity.

This unit meets Chapter 84, Note 5 (D) with regard to disk storage units.

The applicable subheading for the Dragon Series Micro Hard Drives will be 8471.70.4065, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Automatic data processing machines and units thereof…Input or output units, whether or not containing storage units in the same housing: Other: Storage units: Magnetic disk drive units: Other (than for a disk of a diameter exceeding 21 cm): Not assembled in cabinets, and without external power supply: Hard magnetic disk drive units. The rate of duty will be free.

Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.

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 Denise Faingar at 646-733-3010.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division