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NY 885805

May 5, 1993

CLA-2-84:S:N:N1:110 885805


TARIFF NO.: 8473.30.4000

Mr. Leonard W. Lesiak
Karl Schroff & Associates, Inc.
9757 W. Farragut Street
Rosemont, Il. 60018

RE: The tariff classification of IC memory cards from Japan.

Dear Mr. Lesiak:

In your letter dated April 27, 1993, on behalf of Kanematsu USA, you requested a tariff classification ruling.

The merchandise under consideration involves various models of memory cards, such as SRAM, MaskROM, OTPROM, and Flash memory, that are designed for use with various data processing equipment.

The memory cards are the approximate size of a credit card and incorporate connectors, attribute memory, cover panels, write protect switch, and a four-layer circuit board that contains numerous memory chips. The SRAM card can have data freely written and read to and from the card and is most suitable as the storage medium like a floppy disk. The MaskROM card prints the fixed data and programs requiring no rewriting on an IC. The OTPROM card can only be used for writing data once onto the card. The Flash memory card is similar to the SRAM card, since data can freely be written and read to and from the card.

The memory capacity of these cards ranges from 1.5M bytes to 4M bytes of memory, and the SRAM card also requires a backup battery. Noting Legal Note 2 (b) to Section 16 of HTS, these cards appear to be principally used with automatic data processing machines and units thereof.

The applicable subheading for the IC memory cards 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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