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NY 857306

Oct 22 1990

CLA-2-84:S:N:N1:110 857306


TARIFF NO.: 8471.92.30; 8471.93.30; 8473.30.40; 8507.30.00; 8504.40.00; 8471.92.20; 8471.99.30; 8544.41.00; 8542.11.00

Mr. Paul John Crowley
Sharretts, Paley, Carter, & Blauvelt, P.C. 67 Broad Street
New York, N.Y. 10004

RE: The tariff classification of notebook style computer components from Japan.

Dear Mr. Crowley:

In your letter dated October 18, 1990, on behalf of Kanematsu-Gosho (USA), Inc., you requested a tariff classification ruling.

The merchandise under consideration consists of component parts for a model TEMPO LX 386SX/16 notebook computer. These components will be shipped into the United States in four separate shipments, and then assembled into a finished notebook style computer. Finished or unfinished articles of this nature, if of Japanese origin, would be classifiable under subheading 9903.41.15, HTS, and subject to a 100% ad valorem rate of duty. None of the four groups of shipments have the "essential character" of a complete or finished computer.

Group 1 consists of an LCD assembly and top cabinet with a diagonal dimension of 9.75 inches. Also included are an internally mounted hard disk drive and floppy disk drive, and miscellaneous components such as screws, case for a modem and a rear door modem bezel.

Group 2 consists of the mainboard assembly (without the CPU and ROM-BIOS); NiCad battery pack assembly; bottom cabinet; and A/C Adaptor with cable.

Group 3 consists of the keyboard assembly; power supply for mainboard; and cable assembly;

Group 4 consists of the 80-C386-SX-16 central processing unit and ROM-BIOS (AM 27C1024-15).
The applicable subheading for the component parts of these four groups are as follows:



LCD Assembly 8471.92.30 free
Top Cabinet 8473.30.40 free
Hard Disk Drive 8471.93.30 free
Floppy Disk Drive 8471.93.30 free
Miscellaneous parts such as Various eo-nomine - screws, and modem cases, etc. provisions


Mainboard assembly, w/o CPU 8473.30.40 free and ROM-BIOS
NiCad Battery pack assembly 8507.30.00 5.1 percent Bottom Cabinet 8473.30.40 free
A/C Adaptor/cable 8504.40.00 3 percent


Keyboard Assembly 8471.92.20 free
Power Supply for mainboard 8471.99.30 3 percent Cable Assembly 8544.41.00 5.3 percent


Central Processing Unit 8542.11.00 free
(80-C386-SX-16 chip)
ROM-BIOS (AM 27C1024-15) 8542.11.00 free

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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