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NY 872117

March 13, 1991

CLA-2-84:S:N:N1:110 872117


TARIFF NO.: 8471.20.0090; 8524.90.4080

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

RE: The tariff classification of a notebook computer and software from Singapore.

Dear Mr. Heck:

In your letter dated March 4, 1992, on behalf of Epson America Inc., you requested a tariff classification ruling.

The merchandise under consideration involves three models of notebook computers that incorporate a 80386 microprocessor, 2MB of RAM, an internal 3.5 inch 1.44MB floppy disk drive, an integrated keyboard, and a LCD flat panel display. The computer is imported and marketed with a nylon carrying case, and also includes a detachable power cord, two Ni-Cad batteries, one AC/DC adapter, and one software diskette. Epson notebook computer model EO400 is the NB-SL/20 monochrome LCD 20 MHZ version. Model EO401 is the NB-SL/25 monochrome LCD 25 MHZ version. Model EO402 is the NB-SL/25C active matrix color LCD 25 MHZ version. The unit, with one hard disk drive and one battery weighs 6.5 pounds. The keyboard, flat panel display and processor portion are in one common housing.

The nylon carrying case is padded on the inside with two MM polyethylene foam, and includes inside pockets of PVC for holding several software diskettes and thin manuals. The case also has a sturdy carrying handle and a zippered closure on three sides. This case is specially fitted to contain the notebook computer, and is suitable for long-term use. It thus appears to meet the GRI-5 (a) provision and would thus be classified at the same rate as the computer.

The applicable subheading for the three models of notebook computers 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 duty rate will be 3.9 percent ad valorem.

Noting Legal Note 6 to Chapter 85 of HTS, the software disk included in the computer case is classified separately.

The applicable subheading for the user disk software package will be 8524.90.4080, HTS, which provides for other recorded media. The rate of duty will be 9.7 cents per square meter of recording surface.

Your inquiry does not provide enough information for us to give a classification ruling on the color active matrix LCD display unit that is separately imported. Your request for a classification ruling should include descriptive literature on this flat panel display unit, and specifics as to whether this display unit is capable of use with other computers or merely designed for use with the three models of Epson computers. Please clarify also the country of origin for these display units, and whether or not these display panels were assembled in Singapore of Japanese components.

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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