CLA-2-84:RR:NC:1:110 C83834
Mr. Kenneth G. Weigel
Kirkland & Ellis
655 Fifteenth Street, N.W.
Washington, D.C. 20005
RE: The tariff classification of components for model DKU-3051
disk storage units from Japan.
Dear Mr. Weigel:
In your letter dated January 23, 1998, on behalf of Hitachi
Computer Products America, Inc., you requested a tariff
classification ruling.
The merchandise under consideration involves complete disk
storage units, and components and subassemblies of the disk
storage units. The magnetic disk storage unit consists of a
complete and assembled model DKU-3051. Stage 1 of these
shipments will consist of the complete and assembled DKU-3051
disk storage unit. In Stage 2 and Stage 3, the shipments will
consist of parts and subassemblies of the DKU unit, and will be
described as the "L" group and the "M" group components. All of
the "S" parts will be shipped separately from the "L" and "M"
parts, and will be classified individually in accordance with
GRI-1.
The DKU-3051 is the disk drive unit for Hitachi's 7700E
Array Storage Subsystem. This subsystem uses an enhanced
Redundant Array of Inexpensive Disks ("RAID") design, which
allows for continuous storage, backup and maintenance of the
subsystem without having to take the system down. The storage
capacity in the DKU-3051 will be 181 G.B. per DKU and 363 G.B.
per subsystem, and will consist of one DKC and two DKUs. The
DKU-3051 will be able to have 56 Head Disk Assemblies ("HDA") in
each unit.
During Phase 1 the DKU-3051 will be imported in its complete
and assembled form. In Phase 2 and Phase 3, the parts and
subassemblies necessary for subassembly manufacturing and final
DKU-3051 assembly in the United States will be imported. The
parts and subassemblies will be imported in large ("L"), medium
("M"), and small ("S") parts groups.
The "L" parts will consist of: 1 - sheet metal parts for the
frame and door assemblies for the DKU-3051; 2 - the HDU box
assembly which consists of sheet metal parts for the HDU box.
The HDU box assembly will contain up to seven HDAs. 4 - HDAs. A
HDA consists of the platter, head, voice coil motor and spindle
motor in an enclosed housing. After importation, a fan and a
bracket are added to the HDA. To transform a HDA to a HDU, a
read/write or drive main board and DC to DC converter are added
to the HDA. There will be two power supplies per HDU box for up
to 7 HDAs. The power supplies will be produced in the United
States.
The "M" parts will consist of the back panel assembly. The
back panel assemblies are designed and used specifically for the
DKU-3051. As previously noted, the "S" parts for the DKU-3051
will be shipped separately. These parts will be classified in
accordance with GRI-1.
The applicable subheading for the complete and assembled
DKU-3051 will be 8471.70.5065, Harmonized Tariff Schedule of the
United States (HTS), which provides for other hard magnetic disk
drive units. The rate of duty will be free.
The applicable subheading for the "L" parts, which consist
of the sheet metal frame assembly for the frame and door assembly
for the DKU-3051, the sheet metal parts for the HDU box assembly,
and the "M" parts which consist of the back panel assembly, will
be 8473.30.5000, 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 HDAs are also classified as parts under item
8473.30.5000, HTS. The HDAs as imported do not contain the fan,
read/write board, or the power supplies. Without these
components, the HDAs lack the essential character of a disk drive
unit and thus cannot be classified as such.
Therefore, the applicable subheading for the HDAs will be
8473.30.5000, 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.
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,
Robert B. Swierupski
Director,
National Commodity
Specialist Division