CLA-2-84:RR:NC:1:110 D82242
Ms. Carol A. Rafferty
Kirkland & Ellis
655 Fifteenth Street, N.W.
Washington, D.C. 20005
RE: The tariff classification of modified components for model
DKU-3051 disk storage units from Japan.
Dear Ms. Rafferty:
In your letter dated September 16, 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 as it applies to a slightly modified product. The
magnetic storage unit consists of a complete and assembled model
DKU-3051 which has been upgraded.
Modifications in the DKU-3051 slightly alter the specificat-
ions of this magnetic disk storage unit. The maximum storage
capacity will be increased from 360 GB to 765 GB; the data
transfer rate will be increased from 7.6-10.7 MB/second to 10.0-15.3 MB/second; the number of HDAs per unit will be increased
from 56 to 60; and the weight will be increased from 420
kilograms to 428 kilograms.
The "L" and the "M" parts will consist of the same disk
drive components as noted in NY Ruling Letter C83834. As
previously noted, these components will be imported without the
fan, read/write board, and the power supply. Without these
items, the HDA does not contain the "essential character" of a
disk drive unit and cannot be classified as such.
The applicable subheading for the complete and assembled
model DKU-3051 magnetic disk drive unit, with product modifica-
tions as noted above, 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 hard disk unit
box assembly, the Head Disk Assemblies (HDA), 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.
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