NY 882148 - The tariff classification of components for an "InfoPak Information System" from Mexico. - United States International Trade Commision Rulings

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NY 882148

January 28, 1993

CLA-2-84:S:N:N1:110 882148

CATEGORY: CLASSIFICATION

TARIFF NO.: 8473.30.4000; 8471.99.9000; 8471.92.1000; 8524.90.4080

Mr. A. Pranses
Rudolph Miles & Sons
4950 Gateway East
P.O. Box 11057
El Paso, Texas 79983

RE: The tariff classification of components for an "InfoPak Information System" from Mexico.

Dear Mr. Pranses:

In your letter dated January 14, 1992, on behalf of InfoPak Inc., you requested a tariff classification ruling.

The merchandise under consideration involves components of a computer based data system, called the "InfoPak Information System", whose purpose is to give users in remote locations the ability to access information by means of a portable display device. The specific items in the system include an assembled printed circuit board, called an "Internal Card", an external drive, called an "Infoloader", and a portable LCD/keyboard unit called an "InfoReader". Some of these components will also be shipped in a "kit" format and sold and marketed as a retail set. Some of the most common end uses for this system will be real estate offices for displaying real estate listings, or for showing such data as telephone directories, flight schedules or similar data.

The Internal Card is a printed circuit board which will be placed inside of an IBM compatible PC and provides the PC with the hardware capability to address data onto the memory card via the external drive.

The InfoLoader contains a 68 pin memory card connector housed in a stand alone 6.5" x 4.25" x 1.75" metal case. The purpose of this unit is to update the InfoCards via a 50 pin ribbon that connects the InfoLoader to the printed circuit board installed in the PC. This unit is not a storage device since it is designed to transcribe data from the PC onto the InfoCard.

The InfoReader is a hand-held, fold open display device measuring 7.75" x 3.25" x 1.25". On one side of the unit is an LCD display and on the other side is a keyboard with a ten key pad plus directional keys and an enter key. It is battery powered in normal use but does include an AC adapter for outside power. The InfoReader accepts programmed InfoCards and allows the user to bring up on the LCD certain pieces of information contained in the card memory. This unit is therefore a combination display and input device.

The InfoLoader Kit will be imported packaged for retail sale and will contain one Internal Card, one InfoLoader, one ribbon cable, and one diskette of U.S. origin that contains the software driver program that controls the interface between the PC and InfoLoader. Noting GRI-3 (b), the essential character of this set appears to be exemplified by the Internal Card, due in part to its cost and proprietary technical nature.

The InfoReader Kit is made up of one InfoReader and InfoCard, packaged together for retail sale when imported. The InfoCard consists of a flash EPROM memory card of credit card size which in use is inserted into the InfoReader and contains an operating program and the data to be displayed by the InfoReader. Noting GRI-3 (c), this set does not appear to include a component that gives the set its essential character.

The applicable subheading for the Internal Card 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.

The applicable subheading for the InfoLoader will be 8471.99.9000, HTS, which provides for machines for transcribing data onto data media in coded form and machines for processing such data, not elsewhere specified or included. The rate of duty will be 3.7 percent ad valorem.

The applicable subheading for the InfoReader will be 8471.92.1090, HTS, which provides for combined input/output units. The rate of duty will be 3.7 percent ad valorem.

The applicable subheading for the InfoLoader Kit will be 8473.30.4000, 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. The software diskette, noting Legal Note 6 to Chapter 85, will be separately classified under HTS number 8524.90.4080. The rate of duty will be 9.7 cents per square meter of recording surface.

The applicable subheading for the InfoReader Kit will be 8473.30.4000, 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.

Articles classifiable under subheading 8471.99.9000, 8471.92.1090, and 8524.90.4080, HTS, which are the products of Mexico, are entitled to duty free treatment under the Generalized System of Preferences (GSP) upon compliance with all applicable regulations.

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.

Sincerely,

Jean F. Maguire
Area Director

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