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HQ 084649

September 20, 1989

CLA-2 CO:R:C:G 084649 AJS


TARIFF NO: 8471.92.10

Neil R. Andrews
Manager, Corporate Customs
Data General Corporation
Mail Stop C221
4400 Computer Drive
Westboro, MA 01580

RE: Portable computer terminal

Dear Mr. Andrews:

Your letter of May 26, 1989, requesting a tariff classification of a portable computer terminal produced by Nippon Data General has been referred to this office for reply.


The article in question is a portable video display terminal named the "Cardinal". It consists of a keyboard, liquid crystal display, and a modem in a plastic housing. When closed, the article measures 13.2" X 9.6" X 1.8" and weighs five pounds. The liquid crystal display is hinged and tiltable, and when closed covers the keyboard.

The terminal contains parallel (printer) and asynchronous interface ports. Two 8-bit microprocessors which are hard-coded via ROM-base emulators perform terminal emulator functions, battery checking and keyboard scan, manage the real-time clock, control data flow through the modem and perform other housekeeping functions. The terminal also contains 32K-bits of static RAM.

The Cardinal contains no floppy or hard disk drives and is not capable of processing programs or performing arithmetic computations. In fact, the article must be connected to a host computer in order to perform any functions at all for the user.

It is normally used by a traveler to remotely connect to a computer system in the home office. Power is provided by internal batteries or by a wall-current adapter.


Whether the article in question is properly classifiable within subheading 8471.92.10, Harmonized Tariff Schedule of the United States Annotated (HTSUSA), which provides for combined input/output units; or is it more properly classifiable within subheading 8471.20.00, HTSUSA, which provides for digital automatic data processing machines.


Classification under the HTSUSA is governed by the General Rules of Interpretation (GRI's). GRI 1 provides that classification is determined first in accordance with the terms of the headings of the nomenclature and any relative section or chapter notes.

Heading 8471 provides for automatic data processing (ADP) machines and the units thereof. The article in question does not meet the definition of an ADP machine specified in Chapter 84, note 5(A)(a). It cannot execute the required processing programs or perform arithmetical computations. Therefore, this portable computer terminal is not an ADP machine.

However, note 5(B) states that ADP machines may be in the form of systems consisting of a variable number of separately housed units. A unit is to be regarded as part of the complete system if:

"(a) [i]t is connectable to the central processing unit either directly or through one or more other units; and

(b) [i]t is specifically designed as part of such a system (it must, in particular . . . be able to accept or deliver data in a form (code or signals) which can be used by the system).

Such units presented separately are also to be class- ified in heading No. 84.71."

The article in question satisfies these requirements. It is designed to connect to a computer system in the home office and functions principally as a combined input/output unit (i.e. it accepts and delivers data), and it is to be presented separately.

Subheading 8471.92, HTSUSA, provides specifically for "input or output units". This phrase accurately describes the
function of the Cardinal, which is an input unit in that it receives data and converts it into signals and an output unit in that it converts signals into an intelligible display form. Explanatory Note 84.71 (I)(A) states that input and output units may be combined into one signal unit. In addition, subheading 8471.92.10 specifically provides for "combined input/output units". Therefore, the article in question satisfies the terms of the subheading for combined input/output units.

In addition, Explanatory Note (I)(D) states that heading 8471 also covers separately presented constituent units of data processing systems. Examples of these units are additional input and output units (i.e. input-output terminals etc.,). The Cardinal is designed and functions as an additional input/output display terminal. This note gives further indication that additional input/output terminals like the Cardinal are included in this heading.

In sum, the article in question is classifiable as a combined input/output unit. This conclusion is based on the fact that the Cardinal meets the description of a these devices as they are defined within the terms of the relative headings and legal notes.


The Cardinal portable computer terminal is properly classifiable under subheading 8471.92.10, HTSUSA, which provides for other combined input/output units dutiable at the rate of 3.7 percent ad valorem.


John Durant, Director
Commercial Rulings Division

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