CLA-2 CO:R:C:G 088042 JMH
Mr. Alex Romero Jr.
A.F. Romero & Co., Inc.
P.O. Box 989
477 Railroad Blvd.
Calexico, CA 92231
RE: Panel block keyboard for use in a computer printer as a
controller and status indicator; board or panel for the
electric control or the distribution of electricity; control
board, control panel
Dear Mr. Romero:
This is in response to your request for a classification
ruling for certain panel block keyboards to be used in computer
The articles in question are panel block keyboards for use
in computer printers, to be imported from Mexico. The keyboards
consist of mechanisms for making connections to electrical
circuits, and function as both the controller and status
indicator for the printer. The keyboards are able to perform
such functions as on/off, select, print quality, line feed, and
form feed. Additionally, the keyboards' LED's will indicate
various printer status codes.
Whether the panel block keyboard is classified in subheading
8473.30.40, HTSUSA, as "...Parts and accessories of the machines
of heading 8471...Other...", or in subheading 8537.10.00, HTSUSA,
as "Boards, Panels...for electric control or the distribution of
electricity...For a voltage not exceeding 1,000 V..."
LAW AND ANALYSIS:
The classification of merchandise under the HTSUSA is
governed by the General Rules of Interpretation ('GRIs"). GRI 1,
HTSUSA, states in part that "for legal purposes, classification
shall be determined according to the terms of the headings and
any relative section or chapter notes..." The headings in
contention are headings 8473 and 8537, HTSUSA. These headings
describe the following:
8473 Parts and accessories...suitable for use
solely or principally with machines of
headings 8469 to 8472...
* * * * * * * * * * * * *
8537 Boards, panels...consoles...equipped with two
or more apparatus of heading 8535 or 8536,
for electric control or the distribution of
Both headings are within Section XVI, HTSUSA. Section XVI,
Note 2, HTSUSA, states in part the following:
...parts of machines...are to be classified according
to the following rules:
(a) Parts which are goods included in any of the
headings of chapters 84 and 85 (other than heading
8485 and 8548) are in all cases to be classified
in their respective headings;
There is no question that the panel block keyboards are
parts of computer printers. However, it is the opinion of this
office that the keyboards are specifically described as
electrical control boards or panels of heading 8537. In
accordance with Section XVI, Note 2(a), although the keyboards
are parts of certain machines, since they are included in one of
the headings of Chapter 85 the keyboards must be classified in
that heading. The appropriate classification for the block panel
keyboards is subheading 8537.10.00 as "Boards, Panels...for
electric control or the distribution of electricity...For a
voltage not exceeding 1,000 V..."
The block panel keyboards are parts of computer printers.
However, the keyboards are described by a heading of Chapter 85.
In accordance with Section XVI, Note 2(a), machine parts that are
included in a heading of Chapter 85 are to be classified in that
heading. The block panel keyboards are classified in subheading
8537.10.00, as "Boards, Panels...for electric control or the
distribution of electricity...For a voltage not exceeding 1,000
John Durant, Director
Commercial Rulings Division