Mr. Robert L. Eisen
Ms. Karen Bysiewicz
1114 Avenue of the Americas
New York, N.Y. 10036-7703
RE: The tariff classification of a keyboard unit from Thailand.
Dear Mr. Eisen:
In your letter dated December 19, 1995, on behalf of NMB Technologies, you requested a tariff classification ruling.
The merchandise under consideration involves a model number RTx5CTWxx (RT Keyboard Unit). The unit consists of a single housing, and will be complete and fully assembled in its imported condition. The RT Keyboard Unit is specifically designed for interconnection with an automatic data processing (ADP) device, such as a personal or business computer.
The RT Keyboard Unit consists of a keyboard with 104 keys. The main components of the keyboard include the keyboard frame, enclosures, membrane sheets, backplate, logic power board assembly, cord sets, key caps, key switches, and rubber domes.
In addition to the keyboard function, the RT Keyboard Unit can also perform a scanning function. The scanning components are completely incorporated into the keyboard housing. In the scanning application, hard copy documents may be scanned directly into the memory of the computer. The user will have the choice of various scanning speeds that will range between 100 DPI (dots per inch), and 400DPI. The main components providing the scanner capability include the contact image sensor ("CIS"), the CIS housing, the SRAM analog and digital ASIC, a motor and a regulator. The keyboard and the host computer function independently of the scanner function. The user may only access and control the scanning function by using the keyboard.
The RT Keyboard Unit meets the definition of a composite article as noted in GRI-3. This unit is specifically designed and engineered to incorporate both keyboard and scanning components. The subject merchandise also has the appearance of a keyboard. Its keyboard has been designed to be used continuously, whereas the scanning function is designed for use on a much less frequent basis. Therefore, this RT Keyboard Unit appears to also satisfy the definition of GRI-3(b) since its "essential character" is imparted by the keyboard's design characteristics, and apparent principal use as an input device.
The applicable subheading for the model number Rtx5CTWxx (RT Keyboard Unit) will be 8471.60.2000, Harmonized Tariff Schedule of the United States (HTS), 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.
This ruling is being issued under the provisions of Section 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 Art Brodbeck at 212-466-5490.
Roger J. Silvestri