The tariff classification of components for model DKU-2051-

NY A89739 December 3, 1996 CLA-2-84:RR:NC:1:110 A89739 CATEGORY: Classification TARIFF NO.: 8473.30.5000 Mr. Kenneth G. Weigel Kirkland & Ellis 655 Fifteenth Street, N.W. Washington, D.C. 20005 RE: The tariff classification of components for model DKU-2051- 906/901 disk storage units from Japan. Dear Mr. Weigel: In your letter dated November 20, 1996, on behalf of Hitachi Computer Products America, Inc., you requested a tariff classification ruling. The merchandise under consideration involves parts and subassemblies of the DKU-2051-906/901 disk storage unit (DKU) for a central processing unit (CPU). The parts and subassemblies will be imported in large (L), medium (M) and small (S) parts groups. The S parts will be shipped separately from the L and M parts, and will be classified individually in accordance with the appropriate HTS provision as per General Rules of Interpretation (GRI) 1. The L parts will consist of : 1 - The frame assembly which is sheet metal parts for the DKU's frame. 2 - The door assembly which is sheet metal parts for the DKU's door. 3 - The HDU box assembly. These are sheet metal parts for the Head Disk Unit (HDU) box. The HDU box assembly contains seven Head Disk Assemblies (HDA). At the time of importation, it may contain HDAs temporarily mounted in it for shipment. These are removed after arrival in the United States. 4 - HDAs. An HDA consists of the platter, magneto-resistive 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 an HDA to an HDU, a read/write or drive main board and DC to DC converter (DC card power supply) 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 for the disk storage unit. The applicable subheading for the "L" parts, which consist of the sheet metal frame assembly for the frame and door assembly for the DKU-2051-901/906; 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, Harmonized Tariff Schedule of the United States (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 must also be classified as parts under item 8473.30.5000 (HTS). The HDAs as imported do not contain the read/write board nor 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, Harmonized Tariff Schedule of the United States (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, Roger J. Silvestri Director National Commodity Specialist Division