CLA-2-84:S:N:N1:110 872612

Mr. Ken Hashimoto
Expeditors International
P.O. Box 2568
578 Eccles Avenue
South San Francisco, CA 94080

RE: The tariff classification of a computer keyboard from either Hong Kong or Taiwan.

Dear Mr. Hashimoto:

In your letter dated March 11, 1992, on behalf of Unicorn Engineering, Inc., you requested a tariff classification ruling. The merchandise under consideration involves a smart membrane type keyboard that includes seven specific overlays and is compatible with Macintosh, Apple II, IBM, and compatible computers. This keyboard is ideally suitable for people with physical and visual disabilities who need larger keys and less complex keyboards.

This smart keyboard plugs directly into the keyboard port of the computer. The keyboard reads a bar code on the back of the specific overlay that is placed on the face of the keyboard and automatically adjusts. The overlays include such selections as Alphabet, Alphabet and Numbers, Arrows, Numbers, QWERTY, etc. Although this keyboard accommodates people with disabilities, it could also be used in schools and businesses. This keyboard requires no external interfaces, and runs any piece of software that can be run from the standard keyboard.

The applicable subheading for the smart keyboard will be 8471.92.2000, Harmonized Tariff Schedule of the United States (HTS), which provides for other input or output units, such as keyboards. The rate of duty will be free.

This smart keyboard would also appear to be eligible as articles specially designed or adapted for the use or benefit of the blind or other physically or mentally handicapped persons in subheading 9817.0096.

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