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NY 897351

May 4, 1994

CLA-284:S:N:N1:110 897351


TARIFF NO.: 8471.91.0090; 8536.69.0060

Mr. Dennis Heck
Tower Group International, Inc.
5420 W. 104th Street
Los Angeles. CA 90045-6069

RE: The tariff classification of computer cards, and connectors from Japan.

Dear Mr. Heck:

In your letter dated April 22, 1994, on behalf of Epson America, Inc., you requested a tariff classification ruling.

The merchandise under consideration involves three models of credit card size computer cards and two models of connectors, one with an ejector, and one without the ejector.

The CARD-286, CARD-386, and CARD-486 cards, incorporate IBM PC/AT compatible functions that are made possible by micro-assembly technology. The cards are approximately 3.5 inches in length, 2.25 inches in height, and 1/4 of an inch in width. All three models of CARDS consist of an Intel SL superset, VGA controller, Flash ROM BIOS, RAM, floppy drive controller, and a keyboard controller, and can connect to various devices and external peripherals via one of the 236 pin card connectors. These cards can perform similar functions that a full "motherboard" of an ADP system can perform. Noting Legal Note 5 (A)(a) to Chapter 84 of the HTS, these cards would meet the definition of a digital processing unit. These CARDS would normally be connected to such units as hard disk drives, floppy disk drives, LCD flat panel displays, Color LCD flat panel displays, and flash packets.

The connectors, with or without the ejectors, are both 236 pin electrical connectors designed for use with the CARD products. They are used for making electrical connections in a circuit having a voltage of 3 to 5 volts. In most cases equal numbers of cards and connectors are shipped/invoiced together.

The applicable subheading for the three models of computer cards (CARD 286, CARD 386, and CARD 486) will be 8471.91.0090, Harmonized Tariff Schedule of the United States (HTS), which provides for digital processing units, whether or not entered with the rest of a system, other. The rate of duty will be 3.9 percent ad valorem.

The applicable subheading for the two models of connectors will be 8536.69.0060, HTS, which provides for other electrical apparatus for switching or protecting electrical circuits, or for making connections to or in electrical circuits, for a voltage not exceeding 1,000 V.

If like quantities of these cards and connectors are imported together, it would appear that they could be considered a composite good, since they are adapted to each other and are mutually complementary. If such is the case, and noting GRI-3 (b), it would appear that the essential character of this composite article would be exemplified by the computer cards, and thus be classifiable under HTS number 8471.91.0090.

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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