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NY C83199

January 16, 1998

CLA-2-84:RR:NC:1:110 C83199


TARIFF NO.: 8473.30.5000; 5603.93.0090

Ms. Sally Strom
Case Logic, Inc.
6303 Dry Creek Parkway
Longmont, CO 80503

RE: The tariff classification of CD ROM lens and Disk Drive cleaning kits, CD manual cleaning kits, and cleaning wipes from either Taiwan or China.

Dear Ms. Strom:

In your letter dated January 8, 1998, you requested a classification ruling.

The merchandise under consideration involves four items, two of which are 3.5" disk drive cleaning kits, one compact CD manual cleaning kit, and a cleaning wipe for compact discs and computer screens.

Model N-510 is a 3.5" disk drive head cleaning kit that consists essentially of a 3.5" cleaning disk and a bottle of cleaning fluid that is packaged in a blister pack. These are designed for use with computer storage units. The disk is inserted into the disk drive and with the oil, cleans the heads of the disk drives. This kit would meet the definition of a retail set, and the cleaning disk would exemplify the essential character of this set.

Model N2606 is a combination CD ROM lens cleaner, and 3.5" disk drive cleaning kit. It consists of one 3.5" cleaning disk, one CD-ROM disk in a plastic housing, and one bottle of cleaning fluid. The two disks are both designed for use with computer storage devices. The disks are inserted into the storage devices and clean the pickup and heads of the storage units. This model is packaged in a blister pack and also would meet the definition of a retail set. The essential character of this set would be exemplified by the disks, which are basically accessories for the storage units.

The model N-9170 is a compact CD manual cleaner with cleaning fluid. It consists basically of a blister pack that includes a plastic housing and cover approximately 5.5" in length. The interior of the housing has a circular cut-out into which the CD can be placed, and a round cleaning pad that will fit over the CD. It also includes a small bottle of cleaning fluid. The CD is cleaned by rotating the radial action cleaning pad by hand around the surface of the CD, thus removing dirt, dust and oily films from the disc surface. This manual cleaning kit would meet the definition of a set, noting GRI-3 (b) to the HTS.

The cleaning wipe for compact discs and computer screens, model number N-9143, is basically a non-woven piece of material, 4.75" square. Informally weighed, the cleaning wipe was found to be 75g/m2, and appears to be of staple fiber hydro entangled.

The applicable subheading for the model N-510 and N-2606 disk cleaning kits 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 duty rate will be free.

Additional information is required for the model N-9170 compact CD manual cleaner. Please furnish a component breakdown by value for this kit (plastic housing, round cleaning pad, and the cleaning agent). The cleaning agent or fluid requires a 100% composition breakdown. When this information becomes available, you may resubmit your ruling request for that specific model of CD cleaner.

The applicable subheading for the model N-9143 cleaning wipe will be 5603.93.0090, HTS, which provides for other nonwovens, whether or not impregnated, coated, covered or laminated, weighing more than 70 g/m2 but not more than 150 g/m2. The duty rate will be 2.5 percent ad valorem.

The cleaning wipe falls within textile category designation 223. Based upon international textile trade agreements products of Taiwan or China are subject to quota and the requirement of a visa.

The designated textile and apparel categories may be subdivided into parts. If so, visa and quota requirements applicable to the subject merchandise may be affected. Part categories are the result of international bilateral agreements which are subject to frequent renegotiations and changes. To obtain the most current information available, we suggest that you check, close to the time of shipment, the Status Report on Current Import Quotas (Restraint Levels), an internal issuance of the U.S. Customs Service, which is available for inspection at your local Customs office.

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

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