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NY 813679

August 15, 1995

CLA-2-84:S:N:N1:110 813679


TARIFF NO.: 8473.30.5000; 8471.93.3040; 8471.93.3020; 8471.93.5000; 8507.80.8000; 8473.30.1000; 8504.40.80

Mr. Brian F. Walsh
Barnes, Richardson & Colburn
200 East Randolph Drive
Suite 7920
Chicago, Illinois 60601

RE: The tariff classification of computer subassemblies from Japan.

Dear Mr. Walsh:

In your letter dated August 4, 1995, on behalf of Mitsui Comtek Corp., you requested a tariff classification ruling.

The merchandise under consideration involves various subassemblies for lap-top computers, that are separately shipped into the United States and then assembled in the U.S. with other U.S. origin parts.

The subject computer parts and subassemblies include the following groups:

1. Top and bottom chassis that includes the LCD panel assembly and motherboard without a CPU, all physically attached to each other.
2. Keyboard assembly with cable that will fit into housing of lap-top computer.
3. Hard disk drive case (without the drive) Hard disk drive, that does not exceed 21 cm in diameter, and is designed for physical incorporation into the housing of the lap-top computer.
4. Floppy disk drive- is principally used as an internal unit, and is interchangeable within the lap-top in the position of the CD ROM device. Less than 21 cm in diameter. 5. CD ROM drive- is designed for incorporation into the lap-top computer.
6. Lithium battery pack- consists of Lion battery cells and a charging circuit board.
7. Daughter board mounted with CPU, but without BIOS and RAM. 8. AC Cube (actually an AC adapter)

Based on the information provided with the Ruling request, the components and subassemblies are clearly designed and used with a lap-top computer. In its finished state after assembly in the U.S., the computer would fall under the definition of a digital processing unit, as per Legal Note 5 (A) to Chapter 84 of the HTS.

Since these subassemblies will be separately shipped, classification would fall under the following HTS numbers:

Group HTS Duty

1. Top and Bottom Chassis - 8473.30.5000 free 3. H/disk drive case w/o dr- 8473.30.5000 free H/disk drive- internal 8471.93.3040 free
4. Floppy disk drive- int. 8471.93.3020 free 5. CD ROM drive- internal 8471.93.5000 free 6. Lithium battery pack 8507.80.8000 4.8% 7. Daughter board w/o BIOS 8473.30.1000 free 8. AC Cube (AC Adapter) 8504.40.80 2.7%

Regarding the keyboard assembly under group 2, this merchandise is currently before the International Trade Court under Alps Electric USA, Inc. v. United States, Court No. 93-04- 00228. We are therefore unable to issue a ruling on such merchandise at this time.

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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