CLA-2-84:RR:NC:1:110 B85751
Mr. Abraham Gale
Gilar Electronics
1371 S. Beverly Glen #205
Los Angeles, CA 90024
RE: The tariff classification of computer sub-assemblies from Taiwan.
Dear Mr. Gale:
In your letter dated May 7, 1997, you requested a tariff classification ruling.
The merchandise under consideration involves desk-top computer sub-assemblies that will be shipped in various configurations. In all cases they will be without a monitor, thus the issue of a ADP "system" is not applicable.
Item 1- Base personal computer (Model numbers Base TCS-5150 and Base TCS-5950). This consists of a desk-top computer processor sub-assembly and a keyboard. The processor unit includes a chassis, power supply, two disk drives, and motherboard. The motherboard lacks the CPU microprocessor and SIMMS, but includes AMI BIOS and from 8MB of memory to 256MB. The keyboard is a standard PS/2 keyboard, and is a separate and peripheral unit that connects to the processor unit.
Item 2- Base personal computer (Model NMB TCS-5900). This consists of a desk-top computer processor sub-assembly (which includes the chassis, power supply, and floppy disk drive) and a keyboard. The processor unit however lacks the motherboard. As with item one, the keyboard is a standard PS/2 keyboard.
Item 3- Base personal computer (Model NMBK TCS-6610 and NMBK TCS-9345). This desk-top computer sub-assembly consists of a processor unit (chassis, power supply and disk drives), but will not include a motherboard or a keyboard.
Item 4- Motherboard (Model T-5970). This motherboard, which is designed for the various desk-top computers, will be shipped separately but without its CPU microprocessor (normally an Intel Pentium P54C) and without the SIMMS.
Item 1, 2, and 3, in their imported condition, do not have the "essential character" of a complete or finished digital processing unit, noting GRI-2 (a) of the Harmonized Tariff Schedule, and Legal Note 5 (A) to Chapter 84 of the HTS. Note also HQ ruling letters 954411 and 957178, and NY Ruling letters B80848 and B82539.
The applicable subheading for the item 1-3 processor units will be 8473.30.5000, Harmonized Tariff Schedule of the United States (HTS), which provides for other parts and accessories of the machines of heading 8471. The rate of duty will be free.
The applicable subheading for the item 1 and 2 keyboards that are shipped with the processor units will be 8471.60.2000, HTS, which provides for keyboards. The rate of duty will be free.
The applicable subheading for the motherboard without a CPU or SIMMS, will be 8473.30.1000, HTS, which provides for printed circuit assemblies that are parts and accessories of the machines of heading 8471. 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.
Sincerely,
Robert B. Swierupski
Chief, Metals & Machinery Branch
National Commodity
Specialist Division