CLA-2-84:RR:NC:1:110 L87344

Ms. Jennifer Churchill
Hitachi Computer Products (America), Inc.
1800 E. Imhoff Road
Norman, OK 73071-1202

RE: The tariff classification of TagmaStore AMS200 array storage subsystem components from Japan and the Philippines.

Dear Ms. Churchill:

In your letter dated September 2, 2005 you requested a tariff classification ruling.

Your request concerns five components for the TagmaStore AMS200 RAID (Redundant Array of Independent Disks) subsystem. This subsystem is also known as the DF700S. It is marketed for midrange storage applications. The subsystem uses an enhanced array of inexpensive disks design, which allows for continuous storage, backup and maintenance of the subsystem without having to take the system down. It consists of disk storage units (RKAJ or RKAJAT) and a disk control unit (RKS).

The five components are: DF700-RKS – Basic Chassis of Rackmount with Standard Accessory DF-F700-AGF72 – Canister Unit of 71.3 GB Drive DF-F700-ATE400R – Canister Unit of 393.4 GB Drive DF-F700-AGF146 – Canister Unit of 143.3 GB Drive DF-F700-F1JS – Control Unit for RKS The DF700-RKS Basic Chassis is the disk control unit for the DF700 series. Its function is to connect with the data source and then send the data to various hard disk drives (HDDs) in the subsystem. It consists of a frame, panel, and control unit with fibre channel interface, host connector, backup battery unit, fan assemblies, and power units.

The DF-F700-AGF72, the DF-F700-ATE400R and the DF-F700-AGF146 Canister Units are the HDD options. As imported, 3.5” HDDs are installed in these canisters.

The DF-F700-F1JS Control Unit is the RKS controller board. It may be imported as a separate item for replacing a failed board in the DF700-RKS.

The applicable subheading for the DF700-RKS – Basic Chassis of Rackmont with Standard Accessory and the DF-F700-F1JS – Control Unit for RKS will be 8471.80.1000, Harmonized Tariff Schedule of the United States (HTS), which provides for “Automatic data processing machines and units thereof…Other units of automatic data processing machines: Control or adapter units.” The general rate of duty will be Free. The applicable subheading for the DF-F700-AGF72, DF-F700-ATE400R and the DF-F700-AGF146 Canister Units will be 8471.70.4065, Harmonized Tariff Schedule of the United States (HTS), which provides for “Automatic data processing machines and units thereof…Storage units: Magnetic disk drive units: Other: Not assembled in cabinets, and without attached external power supply: Hard magnetic disk drive units.” The general 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 Eileen S. Kaplan at 646-733-3016.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division