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NY B87213

July 9, 1997

CLA-2-84:RR:NC:1:110 B87213


TARIFF NO.: 8473.30.5000; 8473.30.1000; 8504.40.7001; 8507.80.8000

Mr. Peter T. Middleton, Esquire
Middleton & Shrull
44 Mall Road, Suite 208
Burlington, MA 01803-4530

RE: The tariff classification of a notebook computer subassembly and components from Taiwan.

Dear Mr. Middleton:

In your letter dated June 23, 1997, on behalf of NEC Computer Systems Division, you requested a tariff classification ruling.

The merchandise under consideration involves a model number RT6, Versa 2700 Series notebook computer and components. This notebook computer subassembly will include all components except for the lithium-ion or NiMH battery pack, AC adaptor, hard disk drive, and the CPU daughter board with the microprocessor. The daughter board with microprocessor will be imported separately. The hard disk drive will be obtained in the United States. The battery pack and a separate AC adapter will be produced abroad and will be shipped separately from the other components.

The rechargeable battery pack will be either a NiMH 8 cell 1.2V each or a Lithium-ion 8 cell 1.8V each configuration. The AC adapter is an ASTEC ADP52, 45W, 100V-240V. The daughter board contains an Intel Pentium TCP package. It does not contain a BIOS IC which is on the mother board assembly.

The subassembly of the RT 5, VERSA 2700 Series notebook computer, in its imported condition, does not have the "essential character" of a complete or finished digital processing unit, noting GRI-2(a) of the Harmonized Tariff Schedule (HTS), and also Headquarters Ruling Letters 954411 and 957178. NY Ruling Letter B80848 also involved a similar notebook computer subassembly and components. The other components of the RT6, VERSA 2700 are shipped separately, and would be separately classifiable noting Legal Note 2 to Section XVI of the HTS.

The applicable subheading for the RT6, VERSA 2700 subassembly base unit 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.

The applicable subheading for the CPU daughter board, which is separately shipped, will be 8473.30.1000, HTS, which provides for printed circuit assemblies. The rate of duty will be free.

The applicable subheading for the AC adapter will be 8504. 40.7001, HTS, which provides for other power supplies for automatic data processing machines or units thereof of heading 8471, with a power output not exceeding 50W. The rate of duty will be free.

The applicable subheading for the Lithium-ion/NiMH Battery Pack will be 8507.80.8000, HTS, which provides for other storage batteries. The rate of duty will be 4.1 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.


Robert B. Swierupski
Chief, Metals & Machinery Branch

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