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NY 818428





January 29, 1996

CLA-2-84:RR:NC:MA:110 818428

CATEGORY: CLASSIFICATION

TARIFF NO.: 8473.30.1000; 8534.000090; 8471.60.3000

Mr. Bill Senkevich
Tempustech, Inc.
295 Airport Road
Naples, Florida 33942-3522

RE: The tariff classification of various computer boards and display units from Taiwan

Dear Mr. Senkevich:

In your letter dated January 4, 1996, you requested a tariff classification ruling.

The merchandise under consideration involves various models of computer expansion boards and a display unit.

Model PCM-3718 is an analog input module (circuit board) that attaches to a CPU-module. They are connected with other modules to create embedded controllers, data acquisition systems, etc. It is basically an input module board for a computer/controller.

Model PCM-3724 is a digital input/output module (circuit board) that attaches to a CPU module. They are connected with other modules to create embedded controllers, data acquisition systems, etc. It incorporates 48 digital I/O lines, and is pin-compatible with Opto-22 I/O module racks.

Model PCM-3910 is a circuit board with two connectors on it, but incorporates no electronic components on the board. Its purpose is to allow the users to build their own circuits on the board, and provides a convenient form factor/mounting scheme. It will be used with 8-bit or 16-bit applications, and includes holes in the board that are plated through.

Model SBC-350A is a half-size industrial single board computer that normally comes equipped with a 80386SX-40 or 80486SLC-33 CPU. It lacks DRAM memory on the board. The version of the board with 80486SLC has cache memory inside of the processor itself but there are no cache memory chips on the board. The other version of the board does not have any cache memory and does not have any provisions for cache memory. Without the DRAM memory, the board cannot function as a digital processing unit, noting LN 5 A to Chapter 84 of the HTS.

Model SBC-230A is an industrial single board computer on a half-size card. It incorporates a 16 MHz 80286 processor, but is shipped without DRAM memory on the board. There is no cache memory on the board and the board does not have any provisions for cache memory.

The FPM-50CT/CSM are flat panel displays that are designed for various ADP applications in industrial areas. They are portable but are really intended for stationary use as state-of-the-art alternatives to traditional CRT monitors. They are light and compact, have low power consumption, are 9.4 inches in diagonal, and are designed for easy panel or wall mounting. They are color LCD displays (either TFT or DSTN), with a resolution of 640 x 480. These flat panel displays incorporate the types of design characteristics that dedicates their use primarily with ADP output applications.

The PCM-4860 is a single board computer with an on-board Ethernet interface and VGA CRT/flat panel controller. It comes with Award BIOS, but is missing the CPU chip and the DRAM memory, and is also without FLASH disk memory.

The DPM-420 is a flat panel/CRT VGA piggyback module board that connects to the 64-pin piggyback connector on the CPU card, thus taking the place of a traditional plug-in VGA or flat panel controller card. It supports a wide range of popular LCD, EL and gas plasma flat panel displays and traditional analog CRT monitors in high-resolution display modes.

The DPM-410 is a super VGA piggyback module (board) specially designed for all CPU cards which come equipped with a 64-pin piggyback connector. It is compatible with IBM SVGA, VGA, EGA, CGA, and Hercules display adapters.

The RDM-110 is a flash/RAM/ROM disk module (board) specifically designed for industrial grade all-in-one CPU cards which come equipped with a 64-pin piggyback connector.

The applicable subheading for the expansion boards and unfinished single board computer boards (models PCM-3818, PCM-3724SBC-350A. SBC-230A, PCM-4860, DPM-420, DPM-410, and RDM-110), will be 8473.30.1000, 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, printed circuit assemblies. The rate of duty will be free.

The applicable subheading for the PCM-3910 circuit board will be 8534.000090, HTS, which provides for other printed circuits. The rate of duty will be 4.3 percent ad valorem.

The applicable subheading for the FPM-50CT/CSM LCD flat panel display will be 8471.60.3000, HTS, which provides for display units, without cathode-ray tube (CRT), having a visual display diagonal not exceeding 30.5 cm. The rate of duty will be free.

Your comments regarding the classification of the two models of single board computer boards (SBC-260A and SBC-330A) that were ruled on in #816946, are noted. Noting the provisions of Section 177 of the Customs Regulations (19 CFR 177), based on the facts submitted by the inquirer with that ruling request, the classification of those two models was correct. You now state that these two boards appear to include the CPU chips, but still lack the DRAM memory. The classification for these two model boards would remain under HTS number 8473.30.1000, as printed circuit assemblies, and free of duty.

This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177).

A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist Art Brodbeck at 212-466-5490.

Sincerely,

Roger J. Silvestri
Director

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