The tariff classification of a "USB to PS/2 Adapter", models 98188 and 26836, from China

N072998 September 17, 2009 CLA-2-84:OT:RR:E:NC:N1:120 CATEGORY: Classification TARIFF NO.: 8471.80.1000 Ms. Charlotte J Chowning Jasco Products Company LLC 10 E. Memorial Road Oklahoma City, OK 73114 RE: The tariff classification of a “USB to PS/2 Adapter”, models 98188 and 26836, from China Dear Ms. Chowning: In your letter dated August 21, 2009, you requested a tariff classification ruling. The merchandise under consideration are “USB (Universal Serial Bus) to PS/2 Adapters.” They allow a PS/2 keyboard and mouse to connect to a personal computer. Both models measure approximately fifteen inches in length when stretched end to end, with a USB connector on one end, and two color coded, 6-pin mini-DIN PS/2 female connectors on the other end. These devises use an integrated circuit (pre-programmed chip) to actively translate the PS/2 keyboard signal and convert it into a USB keyboard signal for the computer to understand.  The “USB to PS2 Adapter” meets the definition of a “unit” of an automatic data processing (ADP) machine as noted in Legal Note 5 (B) of Chapter 84 to the HTS. The USB is connectable to the central processing unit (CPU), and is able to accept and deliver data. There principal function of inter-connecting a CPU unit to other units of ADP machines provides "control" and "adaption" functions. The applicable subheading for a “USB to PS/2 Adapter,” models 98188 and 26836, will be 8471.80.1000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "Automatic data processing machines and units thereof: Other: Other: Other: Other." The rate of duty will be Free. Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/. 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 Denise Faingar at (646) 733-3010. Sincerely, Robert B. Swierupski Director National Commodity Specialist Division