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NY 873343

April 21, 1992

CLA-2-84:S:N:N1:110 873343


TARIFF NO.: 8471.92.8085

Mr. James McDermott
Flex-Key Corporation
Emerson Avenue
Gloucester, Mass. 01930

RE: The tariff classification of a miniature track-ball mechanism from England.

Dear Mr. McDermott:

In your letter dated April 14, 1992, you requested a tariff classification ruling.

The merchandise under consideration involves three models of track-ball mechanisms (MTB O, MTB 1, and MTB 2) that are designed for use with keyboards for laptop computers. These track-ball devices are mounted inside of the keyboard housing of the laptop computer and are not designed for use as free-standing input units. These track-ball devices are used to control the placement of the cursor at data or menu selections on the computer screen or at the place where data is to be input through the keyboard. The track-balls are approximately 24mm deep and 60mm square, and are mounted to the top plate of the keyboard housing. After assembly into the laptop keyboard housing, the ball mechanism protrudes through the keyboard housing and is normally to the right of the keyboard.

The three models of track-balls meet the definition of a "unit" as outlined in Legal Note 5 (B) to Chapter 84 of HTS, since it is specifically designed for use with an ADP machine and is directly or indirectly connectable to the CPU of the ADP system.

The applicable subheading for the miniature track-ball mechanisms will be 8471.92.8085, Harmonized Tariff Schedule of the United States (HTS), which provides for input units suitable for physical incorporation into automatic data processing machines or units thereof. 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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