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NY 874481

May 19, 1992

CLA-2-84:S:N:N1:110 874481


TARIFF NO.: 8473.30.4000

Mr. Dennis Heck
Castelazo & Associates
5420 West 104th Street
Los Angeles, CA 90045

RE: The tariff classification of a Cupid-32 processor board from Hong Kong

Dear Mr. Heck:

In your letter dated May 11, 1992, on behalf of AST Research, Inc., you requested a tariff classification ruling.

The merchandise under consideration involves a modular design board (Completely Universal Processor and I/O Design) that is designed for use with a line of desktop computers. The CUPID- 32 design modularizes the system board, the processor board and the optional memory expansion board for easy memory and/or microprocessor upgradability. The processor board contains the CPU microprocessor, math coprocessor socket, external cache memory/controller (i.e. cache memory is standard on certain configurations, but not all Premium line processor boards have external cache memory), crystal oscillator, a series of discreet programmable array logic IC's, and the system memory SIMM's (single in line memory modules).

The processor board does not contain the system BIOS, no I/O capability, no system bus, and no peripheral interfaces since all of these functions are resident on the system board (main board). The processor board is thus performing the storage of the processing program, and the arithmetical computations, while the main board performs the programmability functions of the computer through utilization of the resident ROM BIOS, the I/O bus and the keyboard controller.

If the processor board and main board are imported together, noting Legal Note 5 (A) to Chapter 84 of HTS, they would meet the definition of a digital processing machine. The processor board is however imported separately and would not qualify as a digital processing unit.

The applicable subheading for the CUPID-32 processor board will be 8473.30.4000, Harmonized Tariff Schedule of the United States (HTS), which provides for parts and accessories of the machines of heading 8471 not incorporating a cathode ray tube. 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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