Mr. Dipan Karumsi
Allyn International Services, Inc.
6290 Corporate Court, Suite C201
Ft. Myers, FL 33919
RE: The tariff classification of a "Buz" Multimedia Box from either Singapore or Malaysia
Dear Mr. Karumsi:
In your letter dated December 23, 1997, on behalf of Iomega Corporation, you requested a tariff classification ruling.
The merchandise under consideration involves a "Buz" box, that is a desktop unit that provides an easy interface for audio, video, and photo multimedia into a personal computer. When shipped as a complete unit, the finished device includes the following:
1. A break-out box which itself is encased in a plastic box that houses a circuit board and the mounting for the four sets of RCA plugs.
2. A video patch cable that is used to connect the break-out box to an external video source, such as a VCR, video camera, laser disk, DVD, or a television.
3. A SCSI controller card that is installed in the back of a PC and used for connecting the break-out box to the central processing unit. The SCSI card functions to digitize analog signals from video sources.
4. Two CD-ROM software packages for editing and enhancing video, photo, and audio. The disks contain MGI Video Wave SE plus, Picture Works Hot Shots, Iomega RecordIt, and various Tutorials.
The break-out box allows quality real-time motion-JPEG video capture-720 x 480 resolution at 30 fps, through an ultra SCSI controller card which connects to a PCI slot into the back of the CPU. Permanently attached to the box is a 15 position female D-subconnector which connects into the PC through the SCSI card, and two 3.5mm stereoplugs which connect directly to the back of the PC.
The inquirer asks us to rule on the complete finished system, shipped as a kit, when the major components are shipped separately, and when the break-out box and SCSI card only are shipped together.
When shipped as a complete kit and a good put up in sets for retail sale, noting GRI-3 (b), the essential character of this set would be exemplified by the break-out box. The break-out box would meet the definition of a "unit" of an ADP system as per Legal Note 5 (B) to Chapter 84 of the HTS. Noting Ruling letters HQ 955873 and NY C80545, this set would be classified as other units of an ADP system. Noting Legal Note 6 to Chapter 85 of the HTS, the two software disks would be separately classifiable as recorded media.
The applicable subheading for the complete Buz multimedia system will be 8471.80.9000, Harmonized Tariff Schedule of the United States (HTS), which provides for other, other units of an automatic data processing system. The rate of duty will be free.
The applicable subheading for the two CD-ROM disks that are part of the set will be 8524.39.4000, HTS, which provides for other recorded media for reproducing representations of instructions, data, sound, and image. The rate of duty will be 1.9 percent ad valorem.
When the three major components are separately shipped, they would be classifiable as follows:
1. The break-out box- 8471.80.9000 Free of duty
2. SCSI controller card 8473.30.1000 Free of duty
3. Video patch cable- 8544.41.8000 (if V is less than 80) 3.1% 8544.51.9000 ( if V exceeds 80 but not over 1,000 V) 3.1%
When the break-out box and SCSI card are shipped together, but without any other components, and appear to meet the definition of a retail set as per GRI-3 (b), the essential character of this retail set would be exemplified by the break-out box. The applicable subheading for this set will be 8471.80.9000, HTS, which provides for other units of an automatic data processing system. The rate of duty will be free.
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 Art Brodbeck at 212-466-5490.
Robert B. Swierupski