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NY F89327




August 3, 2000

CLA-2-84:RR:NC:MM:110 F89327

CATEGORY: CLASSIFICATION

TARIFF NO.: 8471.70.5065; 8473.30.5000; 8504.40.7012

Mr. Douglas Turnbull
Hitachi America, Ltd.
50 Prospect Avenue
Terrytown, NY 10591-4698

RE: The tariff classification of the DKU-405I disk storage units and its individual subassemblies if imported separately from Japan.

Dear Mr. Turnbull:

In your letter dated June 30, 2000, on behalf of Hitachi America, Ltd., you requested a tariff classification ruling.

The merchandise under consideration involves complete disk storage unit ("DKU-405I"), components and subassemblies of the disk storage units for Hitachi's next generation RAID400 Array Storage Subsystem. The "DKU-405I" is an upgrade of the current DKU-305I. The major differences between the DKU-305I and the DKU-405I are the size and speed of the respective units as well as the storage capacity. The complete and fully assembled hard disk units will be imported with the read/write board, fans and power converters. The DKU-405I, in its imported condition is one cabinet in the RAID400. The frame assemblies of the DKU-405I are sheet metal parts preformed to serve as the exterior of the unit. Part numbers DWG #1505223-A, DWG #1505224-A AND DWG #1505222-B are referred to as "L" parts by Hitachi America, Ltd. and consist of the frame door and box assembly. Part number DWG #1505930-A is a sheet metal part with electrical components i.e. (connectors, capacitors etc.) designed to serve as the back board for the DKU. Part number DWG #5502250-2 is the switching power supply of the DKU. From the information supplied with your ruling request, the power supply has alternate power output ratings of 101W at 5V or 386.4W at 12V. Hitachi refers to the switching power supply and the sheet metal back board as "M" parts.

The applicable subheading for the complete and assembled "DKU-405I" disk storage unit will be 8471.70.5065, Harmonized Tariff Schedule of the United States (HTS), which provides for "Automatic data processing machines and units thereofnot elsewhere specified or included: Storage units: Magnetic disk drive units: Other: Other: Hard magnetic disk drive units." The rate of duty will be free.

The applicable subheading of the frame assembly "L" parts DWG #1505223-A, DWG #1505224-A and DWG #1505222-B will be 8473.30.5000, Harmonized Tariff Schedule of the United States (HTS), which provides for "Parts and accessories (other than covers, carrying cases and the like) suitable for use solely or principally with machines of headings 8469 to 8472: Parts and accessories of the machines of heading 8471: Not incorporating a cathode ray tube: Other." The rate of duty will be free.

The applicable subheading for the switching power supply, "M" part number, DWG #5502250-2, will be 8504.40.7012, Harmonized Tariff Schedule of the United States (HTS), which provides for "Electrical transformers, static converters and inductors; parts thereof: Static converters: Power supplies for automatic data processing machines or units thereof of heading 8471: OtherWith a power output exceeding 150 W but not exceeding 500 W." The rate of duty will be free.

At this time we are unable to provide you with a ruling for the "back board" for the DKU, "M" part number DWG #1505930-A. You may request a ruling on this part by providing a diagram and wiring schematic along with descriptive literature explaining the function of the back board and a list of its electrical components.

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 212-637-7019.

Sincerely,

Robert B. Swierupski
Director,

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