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HQ 964939

February 5, 2002

CLA-2 RR: CR: GC 964939 TPB


TARIFF NO.: 8471.80.10

Mr. Dipan Karumsi
Allyn International Services, Inc.
6290 Corporate Court, Suite C201
Ft. Myers, FL 33919

RE: “Buz” Multimedia System; SCSI Controller Card; NY C83022 Modified.

Dear Mr. Karumsi:

This is in reference to NY C83022, issued to you on January 9, 1998, by the Director, National Commodity Specialist Division (“NCSD”), New York, in response to your letter dated December 23, 1997, on behalf of the Iomega Corporation, requesting the classification of a “Buz” multimedia box under the Harmonized Tariff Schedule of the United States (“HTSUS”). We have had an opportunity to review that ruling and that find it is inconsistent with previous rulings as to the classification of the SCSI controller card. This ruling modifies NY C83022 to the extent noted.

Pursuant to 625 (c), Tariff Act of 1930 (19 U.S.C. 1625 (c)), as amended by section 623 of Title VI (Customs Modernization) of the North American Free Trade Agreement Implementation Act, Pub. L. 103-182, 107 Stat. 2057, 2186 (1993), notice of the proposed modification of NY C83022 was published on January 2, 2002, in the Customs Bulletin, Volume 36, Number 1. No comments were received in response to that notice.


According to your letter, the “Buz” Box is a desktop unit that provides an interface for audio, video and photo multimedia into a personal computer (“PC”). The break-out box allows real-time-motion-JPEG video capture – 729 x 480 resolution at 30 fps, through an ultra SCSI (small computer system interface) controller card which connects to a PCI slot in the back of the central processing unit (“CPU”). Permanently attached to the box is a 15 position female D-subconnector which connects into the PC through the SCSI card, and two 3.5mm stereo plugs which connect directly to the back of the PC.

The finished package includes:

The break-out box itself: a plastic box encasing a circuit board, which is the mounting for the four sets of RCA plugs. The plugs include: right audio In/Out left audio In/Out
S-video In/Out
Composite video In/Out

A video patch cable, used to connect the break-out box to an external video source (ex: VCR; video camera; etc.).

A SCSI controller card, installed in the back of a PC, used for connecting the break-out box to the CPU. The SCSI card functions to digitize analog signals from video sources.

Two CD-ROM software packages for editing and enhancing video, photo and audio.

You had requested classification of the complete system, as well as of all of the major components if imported separately.

NY C83022 determined that the proper classification for the complete Buz multimedia system would be under subheading 8471.80.90, HTSUS. The break-out box, SCSI controller card and video patch cable, when imported separately were classified under subheadings 8471.80.90; 8473.30.10 and 8544.41.80 (if V is less than 80) or 8544.51.90 (if V exceeds 80, but not over 1,000 V), HTSUS, respectively. The applicable subheading for the two CD-ROM disks was 8524.39.40, HTSUS. As a retail set pursuant to GRI 3(b) the break-out box and SCSI card together, are classifiable in subheading 8471.80.90, HTSUS, with the essential character provided by the break-out box.


Are the SCSI controller cards contained within the “Buz” multimedia system properly classified under subheading 8471.80.10, HTSUS, as units of automatic data processing machines, other, control or adapter units, or under 8473.30.10, HTSUS, as parts and accessoriessuitable 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: printed circuit assemblies?


Classification under the HTSUS is made in accordance with the General Rules of Interpretation (“GRIs”). GRI 1 provides that the classification of goods shall be determined according to the terms of the headings of the tariff schedule and any relative Section or Chapter Notes. In the event that the goods cannot be classified solely on the basis of GRI 1, and if the headings and legal notes do not otherwise require, the remaining GRIs may then be applied.

The Harmonized Commodity Description and Coding System Explanatory Notes (“ENs”) constitute the official interpretation of the Harmonized System at the international level. While neither legally binding nor dispositive, the ENs provide a commentary on the scope of each heading of the HTSUS and are generally indicative of the proper interpretation of these headings. See T.D. 89-80.

The HTSUS provisions that are under consideration are as follows: Automatic data processing machines and units thereof:

Other units of automatic data processing machines:

Control or adapter units.

8473 Parts and accessoriessuitable for use solely or principally with machines of heading 8469 to 8472:

Parts and accessories of the machines of heading 8470:

Not incorporating a cathode ray tube:

8473.30.10 Printed circuit assemblies.

SCSI cards are generally printed circuit boards (“PCBs”) populated with a SCSI controller, memory chip that stores identification information, power source, diodes, resistors, capacitors and buffers used for driving current. Generally speaking, SCSI cards allow personal computers to communicate with peripheral hardware such as disk drives, tape drives, CD-ROM drives, printers and scanners faster and more flexibly than previous interfaces. SCSI cards are adapters by virtue of enabling the transfer of data from the host computer to the peripherals and vice-versa, where the data remains intact and the adapting function is to implement the standard protocols on both sides of the transfer. The SCSI card presently at issue also has the additional function of digitizing analog signals from a video source.

As per Section XVI, Note 2(a), (subject to note 1 of Section XVI, note 1 to chapter 84 and note 1 to chapter 85) parts which are goods included in any of the headings of chapters 84 and 85 are in all cases to be classified in their respective headings.

NY 879916, dated November 9, 1992, classified a remote SCSI controller under subheading 8471.99.15, HTSUS (precursor to subheading 8471.80.10, HTSUS), as a control or adapter unit. In operation, these SCSI controllers received commands from the host computer, which were then translated by the controller into proprietary commands to control document scanners. Noting GRI 2(a), this SCSI controller board had the essential character of a finished or complete controller unit that was designed and used with automatic data processing machines.

GRI 2(a) states that any reference to an article shall be taken to include a reference to that article incomplete or unfinished, provided that, as entered, the incomplete or unfinished article has the essential character of the complete or finished article. In this case, the SCSI controller board has the essential character of a finished or complete controller unit that was designed and used with automatic data processing machines.

Legal Note 5(B) to chapter 84, HTSUS, provides guidance regarding units of automatic data processing machines. It states that “[a]utomatic data processing machines may be in the form of systems consisting of a variable number of separate units.” A unit is to be regarded as a part of the complete system if it meets all of the following conditions:

It is of a kind solely or principally used in an automatic data processing system;

It is connectable to the central processing unit whether directly or through one or more other units; and

It is able to accept or deliver data in a form (codes or signals) which can be used by the system.

The Harmonized Commodity Description and Coding System ENs for 84.71 – Automatic Data Processing Machines and units thereof, Part (I) (D) describe separately presented ADP units as follows:

This heading also covers separately presented constituent units of data processing systems. Constituent units are those defined in Parts (A) (Digital machines) and (B) (Analogue machines) as being parts of a complete system.

Apart from central processing units and input and output units, examples of such units include:

Control and adaptor units such as those to effect interconnection of the central processing unit to other digital processing machines or to groups of input or output units which may comprise visual display units, remote terminals, etc.

This category includes channel to channel adaptors used to connect two digital systems to each other.

Signal converting units. At input, these enable an external signal to be understood by the machine, while at output, they convert the output signals that result from the processing carried out by the machine into signals which can be used externally.

The SCSI card presently at issue incorporates both functions of a control and adapter unit and a signal-converting unit. Control and adapter boards usually incorporate signal conversion or signal formatting functions (see HQ 951331, dated September 18, 1992, and HQ 952659, dated October 7, 1992, which modifies the former). The “Buz” box effects interconnection of a PC to the break-out box, which is an ADP unit. The fact that the SCSI card needs to be incorporated within a system housing or chassis does not mandate their classification as a part (see General Electric Company v. United States, 2 CIT 84, 1981). Although it is a part of the “Buz” box, the SCSI card is more fully described by terms of subheading 8471.80.10, HTSUS, and is thus properly classified under that subheading, rather than in subheading 8473.30.10, HTSUS. This decision is consistent with previous Customs classifications on similar merchandise (see NY 879916, November 9, 1992).


For the reasons stated above, by authority of GRI 1 and 2(a), the SCSI controller card is classified under subheading 8471.80.10, HTSUS, which provides for “Automatic data processing machines and units thereof: Other units of automatic data processing machines: Control or adapter units.”

Effect on other Rulings:

NY C83022 is modified to the extent described above, i.e., the SCSI controller card is classifiable as a control or adapter unit of an ADP machine. All other classification determinations in NY C83022 remain unaffected. In accordance with 19 U.S.C. 1625(c), this ruling will become effective 60 days after its publication in the Customs Bulletin.


John Durant, Director

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