CLA-2 CO:R:C:G 084647 AJS

TARIFF NO: 7616.90.00

Mr. Matthew Chang
Assistant Vice President
C. Itoh & Co.(America) Inc.
335 Madison Avenue
New York, New York 10017

RE: Aluminum blanks for computer memory storage

Dear Mr. Chang:

Your letter of May 16, 1989, requesting a tariff classification under the Harmonized Tariff Schedule of the United States Annotated (HTSUSA) has been referred to this office for reply.

FACTS:

The articles in question are aluminum disc ring blanks (alloyed) of various diameters. They are going to be used as the basic material for the manufacture of disc storage memory components of automatic data processing machines (ADPs).

ISSUE:

Whether aluminum disc blanks are properly classifiable under subheading 8473.30.40, HTSUSA, which provides for parts and accessories of the machines of 8471; or are they more properly classifiable under subheading 7606.92.30, HTSUSA, which provides for aluminum plates, sheets and strip, of aluminum alloy, not clad; or are they classifiable under subheading 7616.90.00, HTSUSA, which provides for other articles of aluminum.

LAW AND ANALYSIS:

In rulings of June 28 (HQ 084217) and July 7, 1989, (HQ 084219), Customs ruled that aluminum blanks and substrates for

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computer memory discs are classified as an article of aluminum in subheading 7616.90.00, HTSUSA. The facts in this case are substantially the same as these previous rulings (copies enclosed), which control the disposition of this case.

HOLDING:

For the reasons stated in these previous rulings, disc blanks of aluminum are classified as other articles of aluminum in subheading 7616.90.00, HTSUSA, dutiable at the rate of 5.7 percent ad valorem.

Sincerely,

John Durant, Director
Commercial Rulings Division

Enclosures