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NY 881184

December 17, 1992

CLA-2-84:S:N:N1:110 881184


TARIFF NO.: 8471.99.1500; 8471.99.3200; 8473.30.4000

Mr. Paul Donatelli
Hitachi Transport System (America), Ltd.
2459 West 208th Street
Torrance, CA 90501

RE: The tariff classification of a model MTC510 magnetic tape controller and component parts from Japan.

Dear Mr. Donatelli:

In your letter dated December 14, 1992, you requested a tariff classification ruling.

The merchandise under consideration consists of model MTC510 magnetic tape controller which is a major component of the MT500 series of magnetic tape subsystem. A magnetic tape subsystem is primarily used as a backup storage system. The MTC510 is the controller in the MT500 series of tape subsystems.

The MTC510 is a controller which, as such, performs as an interface between the tape storage unit (MTU) and the CPU. It is functionally inseparable from the storage unit and performs the following functions: 1. interprets and executes commands; 2. controls channels and magnetic tape storage interface functions; 3. furnishes status to the system; 4. performs diagnostic evaluations of the tape controller; 5. performs error detection and correction functions; 6. buffers and compresses data.

The shipments of these controllers will be in two stages: Stage one- a complete and assembled unit; In Stage two- as parts and subassemblies into the United States for subassembly manufacture and final assembly. The "L" group parts are the larger, sheet metal parts of the MTC, and include primarily the side, cover and front assemblies for the outside metal cabinet. The "M" parts group will consist of three assemblies which constitute the power supply: 1. an A/C box assembly; 2. the main DC power supply; and 3. the PCI board. The "S" parts group will consist of the smaller parts necessary for final manufacture of the MTC. In most instances, the "L" and "M" parts groups will be shipped together in Stage two, and the "S" parts will be shipped separately.

The applicable subheading for the complete MTC510 controller in Stage one will be 8471.99.1500, Harmonized Tariff Schedule of the United States (HTS), which provides for control or adaptor units. The rate of duty will be free.

The applicable subheading for the "M" group of three assemblies, which basically represents an unassembled incorporated power supply, will be 8471.99.3200, HTS, which provides for power supplies, suitable for physical incorporation into automatic data processing machines or units thereof. The rate of duty will be free.

The applicable subheading for the "L" and "S" group of parts, with the exception of those that are more specifically provided for under Legal Note 2 (a) to Section 16 of the HTS, will be 8473.30.4000, HTS, which provides for parts and accessories of the machines of heading 8471, not incorporating a cathode ray tube. The rate of duty will be free.

This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177).

A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction.


Jean F. Maguire
Area Director

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