CLA-2-85:RR:NC:1:108 C81313

Mr. Eric S.C. Wang
Dynasty Customs Broker Inc.
1409 San Mateo Ave.
So. San Francisco, CA 94080

RE: The tariff classification of an MGS-110 12-Channel GPS Smart Antenna from Taiwan.

Dear Mr. Wang:

In your letter dated October 31, 1997, you requested a tariff classification ruling on behalf of your client, Mitac Industrial Corp. The subject item is described as an MGS-110 12-Channel GPS Smart Antenna. This product is solely used with a Notebook computer. It is designed to input data through a 9-pin mouse port into a computer. The product's appearance and size (67 x 105 x 32 mm) are similar to that of a computer mouse. Primarily, its function is to a) receive signals from a satellite, b) translate satellite signals into standard NMEA 0183 protocol which can be read by common map software, c) map software, then identify the location of the Notebook computer. The time to first fix on reception of the satellite signal is 1 minute, while reacquisition is 0.1 second. The unit features 1) SIRFstar GPS architecture, 2) 12-channel "All-in-View" tracking, 3) Full-duplex 9-pin D-sub RS-232 port for easy connection with Notebook PC, 4) Support standard NMEA 0183 protocol, 5) Power adapter for standard 12V cigarette lighter in car, and 6) Built-in passive patch antenna. The product is described as an ideal GPS product for car navigation applications.

The applicable subheading for the MGS-110 12-Channel GPS Smart Antenna will be 8526.91.0020, Harmonized Tariff Schedule of the United States (HTS), which provides for [r]adar apparatus, radio navigational aid apparatus and radio remote control apparatus: [o]ther: [r]adio navigational aid apparatus: [r]eception only apparatus. The duty rate will be 2% ad valorem.

Consideration was given to classifying this product under subheading 8473.30.5000, HTS, as you have suggested. However, the product performs a specific function which is provided for in a heading specific to that function.

This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R. 177). A copy of this 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 Harvey Kuperstein at 212-466-5672.

Sincerely,

Robert B. Swierupski
Director
National Commodity
Specialist Division