The tariff classification of a data storage device from Singapore.

NY I83282 June 25, 2002 CLA-2-84:RR:NC:1:110 I83282 CATEGORY: Classification TARIFF NO.: 8471.70.5065 Mr. James Wickstead EGL Eagle Global Logistics, Inc. 991 Supreme Drive Bensenville, IL 60106 RE: The tariff classification of a data storage device from Singapore. Dear Mr. Wickstead: In your letter dated May 20, 2002 on behalf of your client TeraOptix, LP you requested a tariff classification ruling. The merchandise under consideration is the Mine TX2000. The Mine TX2000 is a plastic enclosed handheld, battery powered, personal data storage device measuring approximately 7 inches high by 3½ inches wide and is only 1 inch thick. The TX2000 features a 10GB hard disk drive, 16-Bit PCMCIA port that supports memory card readers, modem, LAN, WLAN, and other 16bit PCMCIA peripherals. Other features included are a 4 line 16 character high contrast LCD panel with back lighting, USB master and slave ports, AC adapter connector, 10 Mbps Ethernet, stereo audio out, audio recording with external microphone, and composite video out for still JPEG, BMP and GIF images. The TX2000 is capable of receiving e-mails, connecting to a digital camera to store digital photos, connecting to a TV screen to view photos, taking voice memos, functioning as a FTP server (File Transfer Program), connecting to a PC (Personal Computer) to download files, and playing and recording MP3s. The TX2000 is predominantly used as a storage unit for a digital camera; however, its principal function is as a storage unit. The Mine TX2000 appears to be a versatile multifunction or composite machine. As noted under Sec. XVI, Note 3 of the Harmonized Tariff Schedule of the United States (HTS), “…machines designed for the purpose of performing two or more complementary or alternative functions are to be classified as if consisting only of that component or as being that machine which performs the principal function.” Essentially, the Mine TX2000 is a 10GB hard drive with myriad ports and a LCD display. It can connect to a PC, a digital camera and other devices as a removable stand alone hard disk drive unit. The 10GB HDD is the component that provides the principal function. Chapter 84, Note 5(D) covers, in part, disk storage units and machines falling to be classified as disk storage units. Goods subject to Chapter 84, Note 5(D), do not have to be solely or principally used with an ADP system. It is sufficient that they have a legitimate use with an ADP system. As per the literature, the Mine TX2000 has such a use. This unit also meets Chapter 84, Note 5(B)(b) and (c) as required by Chapter 84, Note 5(D). The applicable subheading for the Mine TX2000 will be 8471.70.5065, Harmonized Tariff Schedule of the United States (HTS), which provides for “Automatic data processing machines and units thereof…Storage units: Magnetic disk drive units: Other: Other: Hard magnetic disk drive units.” 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 Eileen S. Kaplan at 646-733-3016. Sincerely, Robert B. Swierupski Director, National Commodity Specialist Division