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NY D80313

August 6, 1998

CLA-2-90:RR:NC:MM:114 D80313


TARIFF NO.: 9031.90.5800

Mr. Charles Hardy

Competitive Edge Dynamics

G.P.O. Box 10590

Central, Hong Kong

RE: The tariff classification of chronograph parts and accessories from Hong Kong

Dear Mr. Hardy:

In your letter dated June 24, 1998 you requested a tariff classification ruling on various parts and accessories for the CED Millennium Chronograph.

The chronograph parts and accessories consist of the following items: replacement mounting brackets, replacement sensors, replacement sky screens, an indoor lighting set, light bulbs, a tripod, a carry case, and a PC download cable.

The mounting brackets are stated to be available in 2 foot, 4 foot, 6 foot and 8 foot lengths. You indicate that a table mount plate is also available. The mounting brackets appear to be designed to be used solely or principally with the CED Millennium Chronograph.

The applicable subheading for the mounting brackets will be 9031.90.5800, Harmonized Tariff Schedule of the United States, HTSUS, which covers parts and accessories, of other optical instruments and appliances, other than test benches, other. The rate of duty will be 4.8 percent ad valorem.

We are returning your request for a classification ruling on various chronograph accessories and parts because of non-conformity with the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177). Additional information is required as indicated below. You may resubmit your request for a ruling when the information is available. If you decide to resubmit your request, please include all of the material that we have returned to you.

A complete description of the sensor is required. What type of sensor is being imported; are they light sensors? Also, are they used in any other applications, other than as a sensor for the chronograph?

The replacement sky screens are stated to be the two top diffuser screens and four side screen arms. Are the sky screens optical elements? As an example, are they lenses, mirrors, reflectors, etc.? Are they imported in a mounting or frame? Please explain the function of the sky screens.

Regarding the lighting set, what is the breakdown by value and weight of the component materials used in the lighting set? Regarding the light bulbs, are the bulbs complete light bulbs, or are they glass envelopes? A sample of the light bulb is required in order to determine the classification of the bulb.

Is the carrying case a fitted case, meaning, is it fitted with special compartments for holding the chronograph? Also, will the case be imported in the same shipment with the chronograph, or will the case be imported separately? If imported separately, the case may be considered to be luggage, and a sample of the case will be required in order to determine the proper classification, along with descriptive or sales literature on the item. We will also require a statement as to the composition of the item. Of what materials is it made? If of textile, we require the fiber content of the outer surface of the fabric.

Regarding the tariff classification of the tripod, is this tripod specifically designed for use with the chronograph, or is it a standard 35 mm photographic camera tripod? Of what material is it made? A sample is required in order to classify the tripod.

The PC download serial cable consists of a 9 (male) to 25 (female) pin connector with 6 ft. length cable. You state that this cable connects the chronograph to a computer. We require the voltage rating of the PC download serial cable in order to classify the goods.

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 Barbara Kiefer at 212-



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