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NY K83389

March 2, 2004
CLA-2-84:RR:NC:1:110 K83389


TARIFF NO.: 8471.70.5065

Mr. Richard R. Wohlrab
L.E. Coppersmith Inc.
AIOP 145 Hookcreek Blvd.
Valley Stream, NY 11581

RE: The tariff classification of a photo storage and viewer from Japan.

Dear Mr. Wohlrab:

In your letter dated February 11, 2004 on behalf of your client Nikon Inc., you requested a tariff classification ruling.

The merchandise under consideration is the Nikon “Coolwalker MSV-01” Digital Photo Storage and Viewer. The Coolwalker MSV-01 is a light and compact portable handheld electronic storage device measuring approximately 3.2 inches by 5.1 inches by 1.4 inches. Power is provided by an interchangeable rechargeable Li-ion battery or AC adapter. This device features a 2.5 inch TFT (Thin Film Transistor) active matrix color liquid crystal display (LCD), 30GB hard disk drive, CompactFlash (CF) Card Slot and control buttons. This device allows the user to store and view up to 10,000 digital photos in JPEG Fine format. The Coolwalker MSV-01 is compatible with JPEG, TIFF and other major image file formats including NEF files and may be connected directly to a personal computer (PC) or printer. Pictures may be transferred directly from the Coolwalker MSV-01 to a computer via the Universal Serial Bus (USB) port or from a CF Card. Video outputs include NTSC/PAL selectable providing direct connection to a TV for viewing.

The Coolwalker MSV-01 Digital Photo Storage and Viewer is a freestanding 30GB hard drive unit with an LCD color screen that can connect directly to a PC or TV. The Coolwalker MSV-01 is a composite machine under Section XVI, Note 3. The hard drive is the component that performs the principal function of this device. Therefore, it would be properly classified as a disk storage unit. Noting Chapter 84, Note 5(D), in part, disk storage units that satisfy the conditions of paragraphs (B)(b) and (B)(c) are in all cases to be classified as units of heading 8471. The Coolwalker MSV-01 appears to meet the criteria of Notes 5(B)(b) and (c) in that it is connectable to a central processing unit and is able to accept or deliver data in a form that can be used by the system. As noted above, it also has a legitimate use with automatic data processing systems.

The applicable subheading for the Coolwalker MSV-01 Digital Photo Storage and Viewer will be 8471.70.5065, Harmonized Tariff Schedule of the United States (HTS), which provides for “Automatic data processing machines and units thereof Storage units: Magnetic disk drive units: Other: Other: Hard magnetic disk drive units.” The general rate of duty will be free.

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 646-733-3016.


Robert B. Swierupski

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