CLA-2-84:RR:NC:1:110 D81614
Mr. Weldon Stanley Jones
Peregrine Technologies & Solutions, Inc.
6116 N. Central Expressway, Suite 920
Dallas, Texas 75206-5155
RE: The tariff classification of a computer adaptor from
England.
Dear Mr. Jones:
In your letter dated August 14, 1998, you requested a tariff
classification ruling.
The merchandise under consideration involves a computer
adaptor. This adaptor unit is utilized to insert accurate
date/time information from a Global Positioning Satellite into a
computer operating system. The components of this computer
adaptor consist of two parts: 1) the clock body (containing the
antenna, radio/microprocessor module, clock module, LCD display
and computer interface (module), and 2) the serial connector
cable. These items will be packaged in a single container
weighing 16.2 ounces, but will be repacked in the United States,
and additional components added prior to wholesale and retail
sale.
The antenna of the clock module detects the signals from a
transmitter broadcasting an accurate time signal. The signal
detected by the antenna is received by the radio microprocessor,
which amplifies it and converts it into signals suitable for use
by the clock module. The clock module uses the signal from the
microprocessor to check and if necessary adjust the time provided
by a quartz clock. This time is passed to the computer interface
module and to an LCD display. The computer interface module
converts the signal provided by the clock module into RS-232 data
format for transmittal to the computer via the serial connector.
Signals from the radio controlled clock are received by the
computer by a serial cable connected to a Comm. Port. They are
then processed using specialized software which ensures the
correct day, date and time information is constantly provided to
a file on the computer network which can be read by all machines
on the network. This series of Atomic Radio Controlled (ARC)
Time clocks receive the time signal from a station, and uses the
time to synchronize a network or single computer to the aboslute
correct time. The ARC Time clocks interface to a computer via a
serial port and driver software available for NOVELL, Windows NT,
and other software.
Although the instant computer adaptor unit interfaces with
an automatic data processing (ADP) computer, it is not
principally used with other ADP machines, or groups of input or
output units. HQ 955873 dated March 7, 1994, and HQ 954494 dated
February 9, 1994 are noted. This adaptor unit interface effects
the interconnection of a central processing unit (CPU) computer
or LAN network to Global Positioning Satellites. This computer
adaptor unit also meets the definition of a "composite good" (the
clock body consisting of the antenna, radio/microprocessor
module, clock module, LCD display and computer interface module)
and the serial connector cable) made up of different components
which are described in different provisions of the HTS. Noting
GRI-3(b), the components of this "composite good" are inter-
connected, adapted to each other, and mutually complementary.
The "essential character" of this composite good would be
exemplified by the computer interface module.
The applicable subheading for the instant adaptor unit will
be 8471.80.9000, Harmonized Tariff Schedule of the United States
(HTS), which provides for other units of automatic data
processing machines. 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