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NY A 87832

September 26, 1996

CLA-2-84:RR:NC:MA:110 A 87832


TARIFF NO.: 8473.21.0000

Mr. Robert K. Curlee
RKC Consultants, Inc.
3806 68th Street
Lubbock, Texas 79413

RE: The tariff classification of a silicone elastomer keypad from Hong Kong

Dear Mr. Curlee:

In your letter dated September 17, 1996, you requested a tariff classification ruling.

The merchandise under consideration involves a silicone elastomer keypad that is designed for use with a "Shoppers Calculator".

This keypad consists essentially of 18 silicone elastomer keys attached to a silicone elastomer frame. It is approximately 3 « inches in length, and 2 « inches in width. It is flexible, and the 18 keytops are marked with alpha-numeric lettering. They do not however incorporate any interface electronics, nor do they contain "carbon pills" on the back side of the device. When added to a plastic top case, calculator assembly, plastic bottom case, and screws, a complete calculator will be created.

Noting Legal Note 2 (a) to Section 16 of the HTS, no specific provision appears to exist for this device, in its imported state. Since this device is specifically designed for a calculator, and appears to be principally used with calculators, it would be classifiable as a component part of the calculator.

The applicable subheading for the silicone elastomer keypad will be 8473.21.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for parts and accessories of the machines of 8470 for electronic calculator machines of subheading 8470.10, 8470.21, or 8470.29. The rate of duty will be 3.1 percent ad valorem.

This ruling is being issued under the provisions of Part 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.


Roger J. Silvestri

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