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NY 803342




December 31, 1996

CLA-2-84:S:N:N1:110 803342

CATEGORY: CLASSIFICATION

TARIFF NO.: 8471.93.3040; 8471.93.4050; 8473.30.5000

Mr. Kenneth G. Weigel, Esq.
Kirkland & Ellis
655 15th Street, N.W.
Washington, D.C. 20005

RE: The tariff classification of components for models DKU-881-10 and DKU-F881-904 disk storage units from Japan.

Dear Mr. Weigel:

In your letter dated September 9, 1994, on behalf of Hitachi Computer Products (America), Inc., you requested a tariff classification ruling.

The merchandise under consideration involves complete disk storage units, and components and subassemblies of the disk storage units. The magnetic disk storage consists of a model DKU-881-10 and the DKU-F881-904.

NY Ruling Letter 886637 referred to a DKU 881-310, and the DKU-F881-304. These two models are being supplemented by the DKU-881-10 and the DKU-F881-904. The difference between these two models are limited, and generally relate to larger storage capacity in the head disk assembly. While one of the logic boards in the DKU 881-10 will differ slightly from the DKU-881-310, and three boards in the DKU-F88I-904 will differ slightly from those in the DKU-F881-304, these boards will be produced in the United States. The only imported article which will change is the head disk assembly (HDA).

The HDA will retain the same dimensions but its storage capacity will increase from 2.83GB to 8.5 GB, the number disks will change from 9 to 11, and the head type will change from inductive to magnetro-resistive. The number of heads will also increase from 15 to 19. Despite these changes, the disk diameter remains at 6.5 inches. The head disk assembly will still remain a part of an ADP unit in its condition as imported.

The applicable subheading for the completed DKU-881-10 and the DKU-F88I-904 will be 8471.93.4050, Harmonized Tariff Schedule of the United States (HTS), which provides for other hard magnetic disk drive units. The rate of duty will be 3.7 percent ad valorem.

The applicable subheading for the completed additional DKU-F88I-904s will be 8471.93.3040, Harmonized Tariff Schedule of the United States (HTS), which provides for hard magnetic disk drive units not assembled in cabinets, and without attached external power supply. The rate of duty will be free.

The applicable subheading for the head disk assembly (HDA), the steel cabinet parts, including the sheet metal for the DKU-881 frame and door assembly, the HDU box, and the metal spring (clip) will be 8473.30.5000, Harmonized Tariff Schedule of the United States (HTS), which provides for other parts and accessories of the machines of heading 8471. The rate of duty will be free.

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.

Sincerely,

Jean F. Maguire
Area Director

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