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NY M83407

May 16, 2006

CLA-2-84:RR:NC:1:120 M83407


TARIFF NO.: 8471.60.2000, 8471.80.1000, 8473.30.5000

Mr. Charles Parisi
Parisi Services, Inc.
Customs Brokerage and Freight Forwarding
P. O. Box 91217
Los Angeles, CA 90009

RE: The tariff classification of computer keyboard, USB adapter and keyboard protective skin cover from China

Dear Mr. Parisi:

In your letter dated April 28, 2006 you requested a tariff classification ruling on behalf of your client Typematrix.

The Typematrix EZ-Reach ergonomic keyboard, model 2030 has a power cord attached. Model 2030 measures 5 ¼ inches wide by 12 ½ inches long by ½ inch deep. It connects directly to the central processing unit (CPU) of any personal computer (PC) and can function only when connected to an operating PC. The keyboard relays data to and receives information from the PC. When the PC user depresses a keycap on the keyboard, the keyboard sends a signal to the basic input/output system (BIOS) for translation and then transmitted to the CPU. This signal is then interpreted and used by the PC according to the automatic data processing (ADP) application utilized by the system user. Based upon this information, the subject keyboard meets the terms of chapter 84, note 5(B), HTSUS, and is described as an ADP unit in heading 8471, HTSUS, specifically under subheading 8471.60.2000, Harmonized Tariff Schedule of the United States (HTSUS).

The keyboard is imported with a USB Dual PS/2 adapter. The USB meets the definition of a "unit" of an automatic data processing (ADP) machine as noted in Legal Note 5 (B) of Chapter 84 to the HTSUS. The USB is connectable to the central processing unit (CPU), and is able to accept and deliver data. It also appears to have the principal function of inter-connecting a CPU unit to other units of ADP machines, thereby providing "control" and "adaption" functions.

Separately imported from the keyboard, the transparent silicon skin is a protective cover that completely covers the 2030 model keyboard. This protective cover is 99 percent pure silicon coated on the surface with one percent polyurethane coating. It is silk-screen printed to identify each keycap of the keyboard. The print will reflect a Qwerty or Dvorak-styled keyboard and will be printed in English or Swedish at this time.

Once imported the silicon protective skin will be repackaged with the adapter and keyboard based on the clients order. Although the keyboard will be imported with the adapter, it does not meet the definition of a set because it will be repackaged with the cover.

The applicable subheading for the keyboard will be 8471.60.2000, HTSUS, which provides for other input or output units, whether or not containing storage units in the same housing. The rate of duty will be free.

The applicable subheading for the USB adapter device will be 8471.80.1000, HTSUS, which provides for control and adapter units for ADP machines. The rate of duty will be free.

The applicable subheading for the keyboard protective skin cover will be 8473.30.5000, HTSUS, which provides for Parts and accessories of the machines of 8471: Not incorporating a cathode ray tube: Other. The rate of duty will be free.

Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.

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 Denise Faingar at 646-733-3010.


Robert B. Swierupski

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