CLA-2-84:RR:NC:1:110 C83835
Mr. Kenneth G. Weigel
Kirkland & Ellis
655 15th Street, N.W.
Washington, D.C. 20005
RE: The tariff classification of components for model DKC-3101 controller 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 controller units, in addition to components and subassemblies of the controller units. The controller unit consists of a complete and assembled model DKC-3101. Phase 1 of these shipments will consist of the complete and assembled DKC-3101. In Phase 2, and Phase 3, the shipments will consist of parts and subassemblies of the DKC unit. All of the "S" parts will be shipped separately from the "L" and "M" components, and will be classified individually in accordance with GRI-1.
The DKC-3101 is the controller 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 DKC-3101 is a controller which performs as an interface between the subsystem's storage unit and the CPU. It is functionally inseparable from the storage unit. The DKC basically performs only data transfer functions. The DKC-3101 is an upgrade of the DKC-2101 model, which was the subject of N.Y. Ruling 813723.
During Phase 1, the DKC-3101 will be imported in its complete and assembled form. In Phase 2 and Phase 3 the parts and subassemblies necessary for the subassembly manufacturing and final DKC-3101 assembly in the United States will be imported. The parts and subassemblies will be imported in large ("L"), medium ("M"), and small; ("S") parts group.
The "L" parts will consist of: 1 - the larger sheet metal parts of the DKC-3101. These parts constitute the DKC's frame. These parts will consist of the frame assembly, front and rear door assemblies, and the side cover assembly. The "M" parts will consist of the back panel assembly and the printed circuit board assembly.
The "S" parts will consist of the smaller parts necessary for subassembly and final manufacture of the DKC-3101 in the United States. All of the "S" parts will be shipped separately from the "L" and the "M" parts, and will be classified individually in their appropriate HTS provision in accordance with GRI-1.
The applicable subheading for the complete and assembled DKC-3101 controller units will be 8471.80.1000, Harmonized Tariff Schedule of the United States (HTS), which provides for other control or adapter units for use with automatic data processing machines. The rate of duty will be free.
The applicable subheading for the "L" parts and the "M" parts which consist of the DKC's frame, similar sheet metal parts, and the "M" parts which consist of the back panel assembly and printed circuit boards 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