CLA-2-83:RR:NC:MM:113 C88783

7616.99.5090

Mr. Doug Cook

University Accessories, Inc.

30910 Prestwick Crossing

Cleveland, OH 44145

RE: The tariff classification of computer security items from Taiwan

Dear Mr. Cook:

In your letter dated June 3, 1998, you requested a tariff classification ruling.

The merchandise is a number of items used to secure computers. The DL-3,4,5,6 drive locks are designed to block unauthorized access to any desktop PC or CD drive. The lock consists of two plates, one of which is permanently glued to the botom of the cabinet of the CPU. The second plate contains a key-

operated cam lock. This lock plate fits into the mounted plate and extends over the opening of the disk drive. This prevents any use of the computer by unauthorized people. Although, in this instance, the item is used for a computer, a cam lock is a class or kind of lock usually used on a cabinet, desk or other furniture.

The applicable subheading for the drive locks will be 8301.30.0060, Harmonized Tariff Schedule of the United States (HTS), which provides for padlocks and locks (key, combination or electrically operated), locks of a kind used for furniture, cam locks. The rate of duty will be 5.7 percent ad valorem.

The P/N 223 Standard 8-ft. Cable is a vinyl-coated steel aircraft cable with return loop and eyelet terminal. It can be used to physically bind the computer to a desk.

The applicable subheading for the cable will be 7312.10.7000, Harmonized Tariff Schedule of the United States (HTS), which provides for stranded wire, ropes, cables, plaited bands, slings and the like, of iron or steel, not electrically insulated: other: fitted with fittings or made up into articles. The rate of duty will be 3.4 percent ad valorem.

The P/N 232 Universal mounting barrel is attached to the computer using the existing screws on the computer base. When mounted, it provides an eyelet through which the cable may be run. Similarly, the P/N 234 Sperry Mount of aluminum and P/N 330 Mounting Bracket of steel can be glued to a computer or other equipment so that it may be secured by a cable.

The applicable subheading for the Universal Mounting Barrel will be 8473.30.5000, Harmonized Tariff Schedule of the United States (HTS), which provides for other parts and accessories for the machines of heading 8471. The rate of duty will be free.

The applicable subheading for the Mounting Bracket of steel will be 7326.90.8585, Harmonized Tariff Schedule of the United States (HTS), which provides for other articles of iron or steel, other, other, other,other. The rate of duty will be 3.5 percent ad valorem.

The applicable subheading for the Sperry Mount of aluminum will be 7616.99.5090, Harmonized Tariff Schedule of the United States (HTS), which provides for other articles of aluminum, other, other, other, other. The rate of duty will be 3.1 percent ad valorem.

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 James Smyth at 212-466-2084.

Sincerely,

Robert B. Swierupski

Director

National Commodity

Specialist Division