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HQ 956208

June 16, 1994

CLA-2 CO:R:C:M 956208 MBR


TARIFF NO.: 8471.99.90

Mr. Peter Jay Baskin
Sharretts, Paley, Carter & Blauvelt, P.C. Sixty-Seven Broad Street
New York, N.Y. 10004

RE: "Multichoice Interface 9751" Automatic Data Processing Machine Interface; ADP; Signal Converting Units; HQ 954494; HQ 955873

Dear Mr. Baskin:

This is in reply to your letter of April 7, 1994, on behalf of Lego Systems, Inc., regarding the classification of the "Multichoice Interface 9751," under the Harmonized Tariff Schedule of the United States (HTSUS).


The "Multichoice Interface 9751" (hereafter "Interface") is principally used to interface a freely programmable host Automatic Data Processing ("ADP") machine with various sensors, motors, lamps and sound elements, used with a "Lego Systems" set for educational purposes.

The Interface measures approximately 8 3/4 inches long and is roughly triangular in shape. Its angled front surface is 3 3/4 inches wide, the back is 2 9/16 inches wide, and the base is 3 9/16 inches wide. The housing consists of two molded grey plastic pieces which are held together by four screws. The Interface is powered by a transformer which connects to a socket on the back of the Interface and is included with the device.

On the front of the Interface are seventeen connector ports and a "Stop" button. Eight of the ports are designated "Input" ports, and eight are designated "Output" ports. The remaining port is a test port labelled "On."

To use the Interface, a Macintosh or MS-Dos based ADP must be connected to the device through a standard 9 pin, RS-232 serial port located on the rear of the article. The Interface cannot be
used as a stand alone article. Additionally, separately sold, proprietary Lego Dacta Control Lab software must be loaded on the ADP machine being employed.

Using Lego manufactured components, students or other users can build model robots, dynamometers, bridges, etc., which contain sensors, motors, lamps, or sound elements. These elements can then be controlled by sending digital commands from the ADP machine to the Interface, which converts the signals to analog signals which, in turn, are routed to the appropriate output ports and transmitted to the connected Lego devices.


What is the classification of the "Multichoice" ADP Interface designed for signal conversion between a freely programmable host ADP and external motors, sensors, lamps and sound elements, under the HTSUS?


The General Rules of Interpretation (GRI's) to the HTSUS govern the classification of goods in the tariff schedule. GRI 1 states, in pertinent part:

...classification shall be determined according to the terms of the headings and any relative section or chapter notes...

The Interfaces are prima facie classifiable under subheading 8471.99.00, HTSUS, which provides for ADP control or adapter units.

The Harmonized Commodity Description and Coding System Explanatory Notes (ENs) to the HTSUS, page 1299, define "control" and "adapter" units. EN 84.71(1)(D)(4) states as follows:

(4) Control and adapter units such as those to effect interconnection of the central processing unit to other digital data processing machines, or to groups of input or output units which may comprise visual display units, remote terminals, etc.

The ENs, although not dispositive, should be looked to for the proper interpretation of the HTSUS. See T.D. 89-80, 54 FR 35127, 35128, (August 23, 1989).

While the Interfaces do effect the interconnection of a freely programmable host computer (Chapter 84, Legal Note 5(A) ADP machine), it is not principally used with "other digital data processing machines, or to groups of input or output units...." The Interfaces principally effect the interconnection of a central processing unit ("CPU") to external sensors, motors, lamps and sound elements (which are not classifiable as ADP units as specified by Chapter 84, Legal Note 5(A)).

However, the ENs also define another type of ADP unit, "Signal converting units," page 1300, as follows:

(5) Signal converting units. At input, these enable an external signal to be understood by the machine, while at output, they convert the output signals that result from the processing carried out by the machine into signals which can be used externally.

The instant interface performs the functions described in the EN above. It enables the ADP machine to understand the sensor's signal, while at output they convert the output signals that result from the processing carried out by the ADP machine, into signals which can be used externally by the motors, lamps and sound elements.

For similar rulings regarding the classification of an interface module which functions as an Input/Output between ADP and non ADP machines, see HQ 955873, dated March 7, 1994, and HQ 954494, dated February 9, 1994.

In HQ 955873, the ARINC 429 and 629 VMEbus interface boards were suitable for incorporation into the ADP machine. Therefore, they were classifiable in subheading 8471.99.60, HTSUS. Whereas, the instant Interfaces are not suitable for physical incorporation into an ADP machine or unit thereof. Therefore, they are classifiable in subheading 8471.99.90, HTSUS.


The "Multichoice Interface 9751" is classifiable under subheading 8471.99.90, HTSUS, which provides for: "[a]utomatic data processing machines and units thereof: [o]ther: [o]ther: [o]ther: [o]ther." The rate of duty is 3.7 percent ad valorem.


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