CLA-2-84:OT:RR:NC:1:120
Mr. Ming Chao
Seagate Technology LLC
920 Disc Drive
Scotts Valley, CA 95066
RE: The tariff classification of Array Disk Storage Systems from China
Dear Mr. Chao:
In your letter dated April 15, 2011 you requested a tariff classification ruling.
The merchandise under consideration includes Seagate’s BlackArmor 400 and 440 network file server (NAS) used to store computer files on a local area network. It is known in the industry as a Redundant Array of Independent Disks (RAID) used within a network.
The BlackArmor 400 is a 4-bay storage server imported with a disk control unit without the hard disk drives (HDD) installed. The four drive bays are easily removable for swapping hard drives. It features a cartridge system, which secures an HDD with pins attached to the cartridge in order to slide the cartridge into the drive bay. The HDD connects to the BlackArmor via the SATA II port, and has 4 USB 2.0 host ports to connect peripherals. It has 1.2 GHZ processor, 256 MB RAM. It features dual RJ54 Gigabit Ethernet ports to connect to the network. It plugs to a router via the RJ54 port to enable computers within a network to access the files stored on the BlackArmor server. It is configured with RAID 0/1/5/10 levels of redundancy and JBOD options, and reads speeds up to 69 MBs in RAID configuration. The cabinet measures 6.30 inches in width by 8.15 inches in height by 10.59 inches in depth. The unit is also equipped with cooling fans and power supplies.
The BlackArmor 440 is identical to the BlackArmor 400 in its hardware and software features and overall configuration, but its 4-bay storage server is imported with four pre-installed hard drives.
The applicable subheading for the BlackArmor 400 will be 8473.30.5000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "Parts and accessories…of headings 8469 to 8472: Parts and accessories of the machines of heading 8471: Not incorporating a cathode ray tube: Other." The rate of duty will be free.
The applicable subheading for the BlackArmor 440 will be 8471.70.5065, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "Automatic data processing machines and units thereof…Storage units: Magnetic disk drive units: Other: Other: 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