United States International Trade Commision Rulings And Harmonized Tariff Schedule
faqs.org  Rulings By Number  Rulings By Category  Tariff Numbers
faqs.org > Rulings and Tariffs Home > Rulings By Number > 1993 NY Rulings > NY 886384 - NY 886590 > NY 886517

Previous Ruling Next Ruling
NY 886517

June 1, 1993

CLA-2-84:S:N:N1:110 886517


TARIFF NO.: 8471.99.1500; 8473.30.4000; 8471.93.3040; 8471.99.3200

Mr. Kenneth G. Weigel
Washington Square, Suite 1100
1050 Connecticut Avenue N.W.
Washington, D.C. 20036-5304

RE: The tariff classification of a model DKC 901-3 Disk Controller, and various components thereof, from Japan.

Dear Mr. Weigel:

In your letter dated April 15, 1993, on behalf of Hitachi Computer Products (America), Inc., you requested a tariff classification ruling.
The merchandise under consideration consists of a model DKC 901-3 controller, and various components which will constitute this controller. The DKC 901-3 disk controller is a control unit that connects the central processing unit to the external magnetic disk subsystem. The principal function of the controller is to receive instructions from the CPU and control the data transferred to and from the disk storage units. The DKC 901-3 controller is functionally inseparable from the storage unit. It basically performs only data transfer functions, and is substantially identical to its predecessor, the DKC 801.

The DKC 901-3 is an upgrade to the DKC 801 model, which was the subject of Customs Service Ruling 858126. The standard model will have a larger cache memory capacity than the prior model. The hard disk drive and the floppy disk drive of the DKC 901-3 have been reduced from 5.25 inches to 3.25 inches. This shift to smaller disk drives is the result of general market trends towards smaller units. The disk drives are not imported in cabinets, nor are there any external power supplies attached to them.

The first stage of the importations will involve shipments of complete disk controllers. After the initial complete shipments, the production of the DKC 901-3 control units will be accomplished by the importation of some of the parts and subassemblies necessary for the subassembly manufacture and final DKC assembly in the United States. These parts and subassemblies will be imported in large ("L"), medium ("M"), and small ("S") parts groups.

In Stage 2 and 3, the L group of parts will consist of the rack assembly, front and rear door assemblies, the top and side cover assemblies, and several large hinges.

In Stage 2, the M parts will consist of the back panel assemblies, the hard disk drive onto which the operational software has been copied, and three assemblies which together constitute the power supply. The power supply assemblies are the following: 1) the power distribution box; 2) the AC/DC power supply; and 3) DC/DC power supply cards. In these systems, instead of having all of the traditional computer power supply functions performed in one location, there are three assemblies which perform these functions.

The S parts group in Stages 2 and 3 will consist of the smaller parts necessary for the final manufacture of the DKC 901- 3. In Stage 3, each of the switching power supply assemblies described above will be imported as S parts. The L, M, and S parts groups will not be exported from Japan in one shipment. The S parts will be shipped separately from the L and M parts, and will be classified in accordance with GRI-1.

The applicable subheading for the complete and assembled DKC 901-3 Disk Controller will be 8471.99.1500, Harmonized Tariff Schedule of the United States (HTS), which provides for other control or adapter units for use with automatic data processing machines. The rate of duty will be free.

The applicable subheading for the L parts which consist of the cabinet, frame, and similar metal parts and, the M parts which consist of the back panel assembly 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 hard disk drive will be 8471.93.3040, Harmonized Tariff Schedule of the United States (HTS), which provides for hard magnetic disk drive units not assembled in cabinets, and without attached external power supply. The rate of duty will be free.

The applicable subheading for the power supply assemblies will be 8471.99.3200, Harmonized Tariff Schedule of the United States (HTS), which provides for power supply units suitable for physical incorporation into automatic data processing machines or units thereof. 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

Previous Ruling Next Ruling