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NY 850474

Mar 21 1990

CLA-2-84:S:N:N1:110 850474


TARIFF NO.: 8471.20.0090

Mr. Mark C. Joye
Webster & Sheffield
Texas Commmerce Tower
601 Milam
Houston, Texas 77002

RE: The tariff classification of lap-top computers from Singapore

Dear Mr. Joye:

In your letter dated March 14, 1990, on behalf of Compaq Computer Corporation, you requested a tariff classification ruling.

The merchandise under consideration includes two models of lap-top computers described as the Compaq LTE and the Compaq LTE/286. Both of these models are automatic data processing machines that have the central processing unit, storage, and input/output units in a common housing.

The production and asssembly process in Singapore will entail the use of printed circuit processor assemblies made in Singapore, printed circuit boards, other types of printed circuit assemblies and components and subassemblies purchased in Singapore or imported from various countries. The liquid crystal display module, floppy disk drive, rear display, display bezel, keyboard subassemblies and a battery will be imported to Singapore from Japan. The hard drive subassemblies will be purchased in Singapore and the AC adaptor will come from Malaysia.

The first stage of the assembly and manufacturing process in Singapore involves the stuffing or "populating" of the mother board with various components on both sides of the board and then testing the assemblies for defects. The second stage of the process combines the printed circuit board assemblies with other components to form the lap-top computer.

The country of origin of a product is the country of manufacture, production, or growth of the article. If further work or material is added to an article in another country, there must be a substantial transformation in that country in order to render such other country the country of origin. In this particular case, the stuffing of the boards and the assembly of the computer components in Singapore have substantially transformed the components into a functional lap-top computer whose name, character and use are different from that of the components used in the processing. Prior Customs rulings that are pertinent to this issue can be found in C.S.D. 89-118, and in T.D. 75-230. The country of origin for purposes of marking and dutiability for these lap-top computers would therefore be Singapore.
The applicable subheading for the Compaq LTE and Compaq LTE 286 lap-top computers will be 8471.20.0090, Harmonized Tariff Schedule of the United States (HTS), which provides for digital automatic data processing machines, containing in the same housing at least a central processing unit and an input and output unit, whether or not combined. The rate of duty will be 3.9 percent ad valorem.

This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177).

A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction.


Jean F. Maguire
Area Director

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