CLA-2-84:S:N:N1:110 807998

Mr. Ernesto Jocson
Unitrans International Corp.
709 South Hindey Avenue
Inglewood, California 90301

RE: The tariff classification of a hard disk drive from Singapore.

Dear Mr. Jocson:

In your letter dated March 9, 1995, on behalf of Kingston Technology Corp., you requested a tariff classification ruling. The merchandise under consideration involves a "Viper 170" hard disk drive. This is an internal disk drive which measures approximately 2.1-inches in width by 3.4-inches in height, and has a depth of approximately 0.4-inches. This hard disk drive is designed to be used with a notebook or desktop computer.

The "Viper 170" hard disk drive has a formatted capacity of 170.8 megabytes. It uses an ultra-smooth recording media, allowing the read/write heads to fly closer to the disk surface, thereby increasing areal density. The "Viper 170" is designed for connection into the PCMCIA slot of the notebook, or desktop computer, and is not encased or attached to an external power source. This hard disk drive therefore has the essential character of an incorporated unit, as opposed to a free-standing unit. The applicable subheading for the "Viper 170" hard disk drive will be 8471.93.3040, Harmonized Tariff Schedule of the United States (HTS), which provides for hard magnetic disk drive units not assembled in cabinets, and without attached external power supply. The rate of duty will be free.

This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177).

A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction.

Sincerely,

Jean F. Maguire
Area Director
New York Seaport