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HQ 086194

January 10, 1990



TARIFF NO.: 8529.90.35

Judy T. Fujii
Import Administrator
Mitsubishi Consumer Electronics America, Inc. 2001 East Carnegie Avenue
Santa Ana, California 92705

RE: Unit Optical Assembly

Dear Ms. Fujii:

This letter modifies Headquarters Ruling Letter 083361 (HQ 083361), dated October 4, 1989 in accordance with the Customs Regulations. 19 C.F.R. section 177.9 An error was made in the classification of merchandise in the former ruling and it is no longer effective. The following ruling should be substituted for HQ 085568.


The merchandise in question, unit optical assemblies, are used in projection color television receivers. The assemblies' function is to produce the color picture and optically project the picture to the screen of the projection color television.

The submitted photos indicate that the imported unit consists of three monochrome picture tubes with deflection yokes. The tubes are fastened together with a bracket. Three mounted lenses are attached to the bracket. The assembly is not wired together and contains no other major components or functions such as amplification, modulation or detection.


Within which heading of the Harmonized Tariff Schedule of the United States Annotated (HTSUSA) should the unit optical assembly be classified?


The classification of merchandise within the HTSUSA is governed by the General Rules of Interpretation. GRI 1, HTSUSA, states in part that "for legal purposes, classification shall be determined according to the terms of the headings and any relative section or chapter notes..."

Chapter 85, Additional U.S. Note 5(a), HTSUSA, states:

Picture tubes imported in combination with, or incorporated into, other articles are to be classified in subheadings 8540.11 through 8540.12, inclusive, unless they are--
(a) incorporated into complete television receivers as defined in additional U.S. note 6 below...

Chapter 85, Additional U.S. Note 6 defines "complete television receivers" as "television receivers, fully assembled in their cabinets, whether or not packaged or tested for distribution to the ultimate purchaser(s)."

The unit optical assemblies in question do not meet the definition of "complete television receivers." Therefore, they must be classified within subheading 8540.11 through 8540.12, HTSUSA. The correct classification is within subheading 8540.12, HTSUSA, as "Thermionic, cold cathode or photocathode tubes... black and white or other monochrome."


The unit optical assembly is properly classifiable within subheading 8540.12, HTSUSA, as "Thermionic, cold cathode or photocathode tubes...black and white or other monochrome."


John Durant, Director
Commercial Rulings Division.

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