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NY R03373

March 16, 2006

CLA-2-:RR:NC:1:120 R03373


Galina Free
Intermec Technologies Corporation
6001 36th Avenue W
Everett, Washington 98203

RE: The tariff eligibility under the United States-Singapore Free Trade Agreement, of Headings 8471 and 8473, HTSUS from Singapore.

Dear Ms. Free:

In your letter dated March 2, 2006 you requested a ruling on the status of goods exported from Singapore under the United States-Singapore Free Trade Agreement (US-SFTA).

In your inquiry, you requested whether the Integrated Sourcing Initiative (ISI) claim is the only claim allowed for goods assembled in Singapore from imported and domestic components and classified under the heading 8471, Harmonized Tariff Schedule of the United States, HTSUS. You also requested whether keyboards classified under subheading 8471.60.2000, HTSUS and thermal printers classified under subheading 8471.60.5500, HTSUS are included in the ISI list and can be entered under the ISI claim. Lastly your inquiry includes whether ISI or SG should be used for parts and accessories of automatic data processing (ADP) machines classified under subheading 8473.30.5000, HTSUS manufactured in Singapore from imported and domestic components and exported from Singapore if these parts qualify for both GN 25(o) and GN25(m) rules and can be entered either under the ISI or SG claim.

The merchandise imported from Singapore entered under heading 8471, HTSUS includes scanners classified under subheading 8471.60.8000, HTSUS and handheld computers classified under subheading 8471.60.5500, HTSUS. All goods are sourced from other countries and manufactured in Singapore.

General Note 25(m), HTSUS, sets forth the criteria for determining whether a good is originating under the US-SFTA. For the purposes of subdivision (b) (ii) of this note, goods that, in their condition as imported, are classifiable in the tariff provisions enumerated in the first column and are described opposite such provisions, when such goods are imported into the customs territory of the United States from the territory of Singapore, shall be considered originating goods for the purposes of this note.

This note, subject to the provisions of subdivisions (m) (26) enumerates the entire heading 8471, HTSUS and the entire heading description, all ADP machines and units classified in heading 8471, HTSUS are to be considered originating goods for the purpose of the agreement. Under subdivisions (m) (27) all ADP machines and units thereof; magnetic or optical readers, machines for transcribing data onto data media in coded form and machines for processing such data, not elsewhere specified or included.

The ISI adapts traditional trade rules to help US and Singapore companies improve the efficiency and flexibility of their global sourcing. For a limited number of Information Technology products listed in Annex 3B of the US-SFTA that already face zero tariffs in the US and Singapore, the ISI eliminates the requirement that these products meet specific “rules of origin” when shipped between the US and Singapore. Per Administrative message 04-0859 issued on 04/08/04, the Automated Commercial System (ACS) was updated in February 2004 to allow automated entry of imports claiming preferential treatment under the US-SFTA. The special program indicator (SPI) “SG” will appear on all entry summaries for which preferential treatment is claimed for non-ISI goods only.

All ISI goods-those goods that appear on the list in General Note 25(m) of the HTSUS will not use the SPI “SG”. Instead, these goods will be entered under the primary tariff number 9999.00.84, and the secondary tariff number (the actual descriptive classification number) will appear on the next line. Even ISI goods with Singapore as the country of origin should be entered using the Chapter 99 number.

Based on the facts provided, the goods described above qualify for US-SFTA preferential treatment, because they will meet the requirements of HTSUS General Note 25(m). The goods will therefore be entitled to a free rate of duty under the US-SFTA upon compliance with all applicable laws, regulations, and agreements.

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/. Amendments to the US-SFTA are provided at http://cbp.gov/xp/cgov/import/international_agreements/us_singapore/.

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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