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NY 814235

September 5, 1995

CLA-2-84:S:N:N1:110 814235


TARIFF NO.: 8471.99.9000

Mr. D. Taylor Pillsbury
Glad & Ferguson
One Sutter Street, 10th Floor
San Francisco, California 94104

RE: The tariff classification of an adapter unit from China.

Dear Mr. Pillsbury:

In your letter dated August 29, 1995, on behalf of Enhance Cable Technology., you requested a tariff classification ruling.

The merchandise under consideration involves an "Enhance" adapter device which is designed for use with a computer in order to allow the user external access and control of the audio output. Each unit consists of a small plastic "box" which measures approximately 1 3/4 inch by 2 5/8 inch by 5/8 inch, which contains a printed circuit board. On the face of the box are two stereo mini jacks and a volume control knob. Another stereo jack is located on the back of the box. A two foot cable connects from the box to a stereo jack which is designed to attach to a sound card or a mini jack located in or on a central processing unit (CPU). Speakers may be attached to the box or headphones.

The "Enhance" adapter device appear to meet the definition of a unit of an automatic data processing (ADP) system, since this adapter is connectable to the central processing unit (CPU) either directly or through one or more units. This device is designed to perform the principal function of effectuating interconnection of the CPU to speakers and/or headphones. Since the speakers and/or headphones are non ADP units, and this device is comparable to a signal converting unit as described in the Explanatory Notes to the HTS on page 1300, consideration under 8471.99.1500 would be precluded. Please note Headquarters' Rulings 955873 and 956208 for similar merchandise.

The applicable subheading for the "Enhance" ADP adapter unit will be 8471.99.9000, Harmonized Tariff Schedule of the United States (HTS), which provides for other, other units for use with automatic data processing machines. The rate of duty will be 3 percent ad valorem.

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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