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NY B82861

March 5, 1997

CLA-2-84:RR:NC:1:110 B82861


TARIFF NO.: 8471.60.9090

Mr. Arvind Suri
J.F. Moran Co., Inc.
475 Douglas Pike
Smithfield, Rhode Island 02917

RE: The tariff classification of a PC Tablet from Hong Kong.

Dear Mr. Suri:

In your letter dated February 26, 1997, you requested a tariff classification ruling.

The merchandise under consideration involves a PC (personal computer) pen and tablet which is designed to operate as a cordless pointing device. The PC Pen is manufactured in the United States, and its classification is not the subject of this ruling request. The overall tablet is approximately 11-inches in length by 10-inches in width, and is 0.75-inches thick. The active area of the tablet is approximately 5.25-inches by 7-inches.

The PC Pen transmits an electromagnetic signal which is used to reveal its location relative to the tablet writing surface. The tablet provides a pointing and writing surface for a cordless pen and a serial mouse. The tablet contains a printed circuit board which incorporates loops forming an X and Y grid pattern to receive the pen transmission. The location and status information, right mouse click, left mouse click, etc., is relayed to the host PC through RS-232 serial interface lines. This connection provides both power to the tablet as well as the position status/data stream. The active pointing area is differentiated from the rest of the tablet surface by finish and/or color treatments.

The PC Tablet appears to incorporate the design characteristics which are common to the input units used with automatic data processing (ADP) applications. Noting Legal Note 5(B) to Chapter 84 of the Harmonized Tariff Schedule (HTS), the PC Tablet would meet the definition of a "unit"of an ADP system. This PC Tablet would also appear to be affected by Legal Note 5 (D) to Chapter 84. This Note specifies that X-Y coordinate input devices, which satisfy the conditions of paragraphs (B)(b) and (B)(c) of Legal Note 5 (B) to Chapter 84, are in all cases to be classified as units of heading 8471.

The applicable subheading for the PC Tablet will be 8471.60.9090, Harmonized Tariff Schedule of the United States (HTS), which provides for other input or output units of automatic data processing machines and units thereof. The rate of duty will be 1.5 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.


Robert B. Swierupski
Chief, Metals & Machinery Branch

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