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NY 860833

March 1, 1991

CLA-2-84:S:N:N1:110 860833


TARIFF NO.: 8471.20.0090; 8471.99.9000

Mr. Marty Langtry
Castelazo & Associates
5420 West 104th St.
Los Angeles, CA 90045

RE: The tariff classification of a Notebook computer and docking station from Taiwan.

Dear Mr. Langtry:

In your letter dated February 19, 1991, on behalf of Epson America, you requested a tariff classification ruling.

The merchandise under consideration includes a model NB3s Notebook computer with its slip cover and an expansion unit.

The NB3s Notebook computer is a portable personal computer that incorporates a 80386SX, 16MHz microprocessor and a 20 MB hard drive mechanism. The keyboard and the computer display is integrated in the same housing as the processor unit. The display unit is an LCD flat panel display that provides VGA graphics with 640 x 480 resolution and displays up to 16 gray scales. The unit also includes a high capacity, 1.44MB, 3.5 inch floppy disk drive, and the computer weighs just 5.8 pounds. The unit comes with a battery pack, AC adaptor/battery charger and DOS 4.01, all standard. The Notebook computer will be imported and sold with its slip cover that is specially shaped and fitted for the NB3s. The cover is constructed of a nylon shell coated with PVC, and the inside of the cover is padded with foam. This slip cover appears to meet the GRI-5 (a) provision and would thus be classified at the same rate as the computer.

The Expansion unit or docking station is in a separate housing from the Notebook computer and provides the following three functions when attached to the NB3s computer:

1. provides a mounting bay for additional and removable hard disk drives
2. provides two AT compatible 16/8-BIT expansion slots 3. provides a power supply for the Notebook computer.

The expansion unit also has the ability to power a full-size external keyboard. This expansion unit appears to meet the definition of a "unit" for an automatic data processing machine, noting Legal Note 5 (B) to Chapter 84 of the Harmonized Tariff Schedule of the United States.

The applicable subheading for the Notebook computer and slip cover will be 8471.20.0090, Harmonized Tariff Schedule of the United States (HTS), which provides for digital automatic data processing machines, containing in the same housing at least a central processing unit and an input and output unit, whether or not combined. The rate of duty will be 3.9 percent ad valorem.

The applicable subheading for the Expansion unit (docking station) will be 8471.99.9000, HTS, which provides for other units of automatic data processing machines. The rate of duty will be 3.7 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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