CLA-2-84:RR:NC:1:110 C87149

Mr. Lee Silberzahn
Sony Electronics Inc.
1 Sony Drive
Park Ridge, N.J. 07656-8003

RE: The tariff classification of a tape drive from Japan.

Dear Mr. Silberzahn:

In your letter dated April 17, 1998, you requested a tariff classification ruling.

The merchandise under consideration involves a model DRV-1000 tape drive. This drive unit is designed to be fitted in the 5.25 inch standard floppy bay slot of a personal computer. This device is able to retrieve and store digital information on a separately purchased magnetic tape cassette.

The DRV-1000 tape drive can record only when used with separately supplied controller hardware contained in an external device that controls the source of the video signal. Connections between the drive and the computer are located on the back of the drive. The DV in/out port connects to an interface board. Power for the drive is obtained from the computer through the port labeled +5 GND+12V. The eject port allows the user to insert and reject the tapes using the button on the front of the drive.

The model DRV-1000 tape drive appears to incorporate the design characteristics which are similar to other internal storage units used with automatic data processing (ADP) machines. Noting Legal Note 5(B) to Chapter 84 of the HTS, this internal tape drive would therefore meet the definition of a "unit" of an ADP system.

The applicable subheading for the internal model DRV-1000 tape drive will be 8471.70.6000, Harmonized Tariff Schedule of the United States (HTS), which provides for other storage units, not assembled in cabinets for placing on a table, desk, wall, floor or similar place. 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
Director,
National Commodity
Specialist Division