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NY E89896

December 8, 1999

CLA-2-85:RR:NC:MM:109 E89896


Mr. Douglas Turnbull
Corporate Import/Export Manager
Hitachi America, Ltd.
Import/Export Office
50 Prospect Avenue
Tarrytown, NY 10591-4698

RE: The tariff classification of Unassembled Printed Circuit Boards from Japan

Dear Mr. Turnbull:

In your letter dated November 11, 1999, you requested a tariff classification ruling.

The merchandise is described in your letter as unassembled printed circuit boards. The main use of the finished boards will be for telecommunication in Private Branch Exchange Switching Apparatus. The unassembled printed circuit boards are composed of electronic components that will be shipped together in manufacturing kits to be used in the assembly of the finished PCA’s. The following are brief descriptions of each type of manufacturing kit:

· TERMA: Highway Transistor for Speech Path Module · BATA: Battery Backup
· ALMTA Alarm Board
· DSPTA: Display Board
· HDDPA: PCB for Hard Drive
· FDDPA: PCB for Floppy Drive

You inquire as to whether these kits can be classified as unassembled PCA’s in heading 8517. In HQ 081999, Customs held that because the goods were packaged in bulk for an assembly operation, they could not be classified as unassembled goods imported as “kits”. Customs further held that the components were classified separately under the appropriate headings of the Harmonized Tariff Schedule of the United States (HTSUS). Components imported in bulk are not “unassembled” within the meaning of GRI 2(a). Therefore, the components are classified separately under the applicable HTSUS provisions.

The information that you have provided is insufficient for classification of the components. Rulings are limited to 5 items per request. When this information is available, you may wish to consider resubmission of your request. If you decide to resubmit your request, please include all of the material that we have returned to you and mail your request to U.S. Customs, Customs Information Exchange, Room 437, 6 World Trade Center, New York, NY 10048, attn: Binding Rulings Section.

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 Eileen S. Kaplan at 212-637-7048.


Robert B. Swierupski

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