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NY B86058

June 4, 1997

CLA-2-84:RR:NC:1:110 B86058


TARIFF NO.: 8471.70.6000

Mr. Robert Chao
BJ Customs Brokerage Co.
P.O. Box 91034
Los Angeles, CA 90009-1034

RE: The tariff classification of CD ROM drives from Japan, Malaysia, Thailand, and Indonesia

Dear Mr. Chao:

In your letter dated May 16, 1997, on behalf of Teac America Inc. you requested a tariff classification ruling.

The merchandise under consideration involves various models of CD ROM drives (models PD-518E; CD-38E; CD-516E) that are basically storage units designed for desk-top and notebook computers.

These models of CD-ROM drives are for use as internal storage units, since they are designed for incorporation within the floppy drive bay slot of desk-top and notebook computers. Model PD-518E combines PD technology and CD-ROM drive technology, with 650 MB data capacity, and 8X performance. It incorporates ATAPI interface capability and motorized tray loading. The front panel includes a volume control, headphone jack, PD/CD indicator, busy indicator, and eject/inject button.

Model CD-38E (8X) is a compact and slim CD-ROM drive that is designed for internal use with notebook computers. It is a 8X performance drive, has 190msec access time, and 1.2MB/sec data transfer rate.

Model CD-516E CD-ROM drive is a high performance plug and play compatible drive unit that incorporates 2.4MB/sec transfer rate, and runs at a 16X performance level. This model includes an IDE/ATAPI interface with a 128KB buffer, and has an access time of 150msec.

The three models of CD-ROM drives are designed and principally used as computer storage devices. They meet the definition of a "unit" as per Legal Note 5 (B) to Schedule 84 of the HTS.

The applicable subheading for the three models of CD-ROM drives will be 8471.70.6000, Harmonized Tariff Schedule of the United States (HTS), which provides for other storage units, not assembled in cabinets for placing on a table, desk, wall, floor or similar place. The rate of duty will be free.

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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