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NY 875496

JULY 23, 1992

CLA-2-84:S:N:N1:105 875496


TARIFF NO.: 8442.40.0000, 5911.90.0000

Mr. Robert S. Kirschenbaum
Kroy Inc.
P.O. Box C-12279
Scottsdale, AZ 85267-2279

RE: The tariff classification of parts for the Duratype 240 SE Digital Lettering System from Singapore and Japan

Dear Mr. Kirschenbaum:

In your letter dated June 12, 1992 you requested a tariff classification ruling.

The four parts you will import are: a mother printed circuit board (pcb) on which numerous electronic components are mounted, the primary component being a microprocessor which controls and coordinates all functions of the machine; a memory printed circuit board which provides power and additional font data to the mother pcb for user variation of typestyles; a keyboard assembly arranged in either the Universal QWERTY configuration or the French AZERTY one. Like a computer or typewriter one, the Duratype 240 SE keyboard is used to input alpha-numeric information; and a felt washer, which provides the desired friction in a slip clutch assembly, its drag in its installed configuration controlling the ribbon rewind. The washer is a product of Singapore; the other three of Japan.

You advocate classification of all four parts in subheading 8442, where, in ruling 873671, we held the complete Duratype 240 SE to be classifiable. The classification of machinery parts, however, is controlled by the Section XVI Notes (copy included). Section XVI Note 1(e) excludes articles of textile material. Section XVI Note 2 governs the classification of parts not excluded by Note 1.

Since the three parts other than the washer are not goods included in any of the headings of Chapter 84 and 85, and are suitable for use solely with the Duratype 240 SE, the applicable subheading for them will be 8442.40.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for other parts of machinery, apparatus and equipment for typesetting. This provision is free of duty.

The applicable subheading for the felt washer will be 5911.90.0000, which provides for other textile products and articles, for technical uses. The rate of duty will be 7.5 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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