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NY N012241

June 19, 2007



TARIFF NO.: 8544.42.2000

Tami Nelson
Import Supervisor
Targus, Inc.
1211 N. Miller Street
Anaheim, CA 92806

RE: The tariff classification of the Targus Retractable Phone/Ethernet & USB Cord (item # ACC80US) from China.

Dear Ms. Nelson:

In your letter dated May 24, 2007, you requested a tariff classification ruling.

The item concerned is the Targus Retractable Phone/Ethernet and USB Cord (item # ACC80US). This article is comprised of a plastic housing that measures approximately 3.95 inches long x 2.75 inches wide x .88 inches thick. Within this housing are two separate cables, a USB cable, which measure approximately 5 feet long, and an Ethernet/phone cable, which measure approximately 6 ½ feet long. The USB cable consists of four individually insulated copper wires in a parallel configuration. One end of this cable incorporates a standard USB type A connector while the opposite end incorporates a USB type B connector. The Ethernet cable consists of eight individually insulated copper wires in a twisted-pair configuration. Both ends of this cable incorporate RJ-45 modular Ethernet connectors. Each of these cables are wound on their own separate spool which is connected to individual springs. This allows each cable to independently retract into the housing.

Included with this item are several converters/adapters. There are two adapters that allow the conversion of the RJ-45 modular Ethernet connectors to RJ-11 modular telephone connectors. This option, changes the networking cable into a telephone cable allowing the user to connect a computer to either an Ethernet network or directly to a phone line. There is an RJ-11 coupler which allows the conversion of the telephone cable into a telephone extension cable. The last adapter allows for the conversion of the USB B connector to a 5-pin mini connector. This combination telephone, networking (Ethernet) and USB retractable cable allows the user to connect their computer to most USB peripherals and networks.

The applicable subheading for the Targus Retractable Phone/Ethernet & USB Cord (item # ACC80US) will be 8544.42.2000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “ Insulated wire, cable: Other electric conductors, for a voltage not exceeding 1,000 V: Fitted with connectors: Other: Of a kind used for telecommunications”. 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 Steve Pollichino at 646-733-3008.


Robert B. Swierupski

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