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NY B87809

July 28, 1997



TARIFF NO.: 8471.30.0000; 9017.80.0000; 8524.91.0030

Ms. Nancy Ridealgh
Racal Technologies, Ltd.
4 Lansing Square, Suite 113
North York, Ontario
M2J 5A2

RE: The tariff classification of components for a CAD Surveyor System from Canada, Japan, and Switzerland.

Dear Ms. Ridealgh:

In your letter dated July 21, 1997, you requested a tariff classification ruling.

The merchandise under consideration involves components of the CAD Surveyor System which is basically a portable system capable of producing fully layered "as is" CAD drawings in the field. The components include CAD Surveyor software, a Fujitsu-Stylistic 1000 mobile processor unit, and a Leica Disto hand-held laser meter.

The CAD Surveyor software is Windows 95 based software that will be on 3.5" disks. It is used to create fully layered drawings complete with every attribute important to a project, accurately positioned and described. It is loaded onto the Fujitsu-Stylistic 1000 pen based tabled PC, although it can also run fully featured on a portable or desktop computer to complement any CAD application. This software does not have the ability to reproduce sound or image.

The Fujitsu-Stylistic 1000 is a PC tablet type of processor unit that is powered by an Intel 486 DX2-50 microprocessor with 32-bit power. This mobile computer incorporates a Windows 95 operating system, incorporates an 8" DSTN color LCD display, 512KB Flash ROM memory, and 8 MB DRAM standard memory. It weighs approximately 3.5 pounds, and has standard interfaces for printers, CD-ROMS, modems, bar code wands, and other peripherals. It was specifically designed for mobile applications requiring graphical information such as maps, blue print drawings, medical diagnostics and more. It is however fully capable of being used for typical office related data processing functions such as word processing or spreadsheets. Noting Legal Note 5 (A) to Chapter 84 of the HTS, this device would meet the definition of a digital processing unit.

The Leica Disto is a hand-held laser meter used to measure lengths, widths and heights at distances of up to 30 meters without using a reflector. The user uses the visible laser beam to target the object without touching it. At the press of a key, the Disto calculates the distance to the laser target point and displays the result digitally, to the millimeter. The device has a LCD display, full icon touchpad, and a built-in NiCd battery which provides approximately 400 measurements. It has a laser diode light source, weighs approximately 1 3/4 pounds, does not incorporate optical elements, and is primarily used at construction sites and for other field measurement work. It is sold as an option device to the CAD Surveyor system and therefore may not be marketed or imported with every CAD Surveyor system.

The components of this system would not meet the definition of goods put up in sets for retail sale, noting GRI-3 (b). Noting Legal Note 6 to Chapter 85 of the HTS, the software has to be separately classified.

The applicable subheading for the CAD Surveyor software disks will be 8524.91.0030, Harmonized Tariff Schedule of the United States (HTS), which provides for other recorded media, prepackaged software for ADP machines, of a kind sold at retail. The rate of duty will be 2.6 cents per square meter of recording surface.

The applicable subheading for the Fujitsu-Stylistic 1000 computer will be 8471.30.0000, HTS, which provides for portable digital automatic data processing machines, weighing not more than 10 kg, consisting of at least a central processing unit, a keyboard and a display. The rate of duty will be 2 percent ad valorem.

The applicable subheading for the Leica Disto laser meter will be 9017.80.0000, HTS, which provides for other instruments for measuring length, for use in the hand, not specified or included elsewhere in this chapter. The rate of duty will be 5.3 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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