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NY 858126

Nov 23 1990

CLA-2-84:S:N:N1:110 858126


TARIFF NO.: 8471.99.1500

Mr. Terry Moran
Hitachi Transport System (America), Ltd.
1800 W. 220th Street
Torrance, CA 90501

RE: The tariff classification of a model DKC 801-2 Disk Cache Controller from Japan.

Dear Mr. Moran:

In your letter dated November 7, 1990, on behalf of Hitachi Transport System, you requested a tariff classification ruling.

The merchandise under consideration consists of model DKC 801-2 controller which is a control unit that connects the central processing unit to the external magnetic disk subsystem. The principal function of the controller is to receive instructions from the CPU and control the data transferred to and from the disk storage units. A magnetic disk subsystem consists of a control unit or DKC, and various varieties of storage devices known as a DKU. The DKC basically performs only data transfer functions, and is substantially identical to its predecessor, the DKC 801-1.

All parts and components imported for the production of the DKC 801-2 controller are separated into one of three groups; "L" (Large), "M" (Medium), and "S" (Small). The "L" group are basically large frame and cabinet assemblies. The "M" group consists of specialized components such as 8 inch floppy disk drives and platter assemblies. The "S" group is for the most part comprised of smaller components for making the subassemblies, such as boards, resistors, and integrated circuits. The three groups of parts and components will be imported together, and represent essentially all of the necessary parts for the assembly of the DKC 801-2. Noting GRI 2 (a) to the HTSUS, these shipments constitute an unassembled and unfinished control unit in its imported condition. Since almost all of the components are present at time of importation, the shipment has the essential character of a finished controller.

The applicable subheading for the unassembled DKC 801-2 disk control unit will be 8471.99.1500, Harmonized Tariff Schedule of the United States (HTS), which provides for other control or adapter units for use with automatic data processing machines. The rate of duty will be 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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