Mr. Machiko Celli
Nippon Express USA, Inc.
PO Box 2487
250 Utah Avenue
South San Francisco, CA 94080-6801
RE: The tariff classification of Notebook computer sub-assemblies from Japan and Hong Kong
Dear Mr. Celli:
In your letter dated April 23, 1996, on behalf of Kanematsu USA, Inc., you requested a tariff classification ruling.
The merchandise under consideration involves components for a Sotec S3 Notebook computer that is shipped in a broken down sub-assembly format and separately boxed. The complete S3-M1000 computer will not be separately shipped. It will be shipped as part of the sub-assembly format but without the CPU board and also without the storage (HDD) power supply components.
The sub-assemblies will consist of a main unit without the CPU board; AC adapter; battery unit; keyboard without integrated circuits; floppy disc drive (internal); and a base unit. The CPU daughter board with CPU will be separately shipped.
The main unit (S3-M1000) consists essentially of the daughter boards socket; PCI bus architecture, 16 MB on board standard memory, PCMCIA card interface, hard drive slot, SVGA TFT color LCD display of 11.3 inches, and a "glide point" pointing device.
The AC Adapter (S3-M2000) is an external device that has a capacity of 43 W, input voltage of 100V-240V, and an output voltage rating of 19V.
The main battery pack (S3-M3000) is a recharcheable, LilON type battery with a voltage of 14.4V.
The keyboard device (S3-M4000) consists essentially of the top half of a keyboard with keytops, metal frame and cable. It does not incorporate any IC chips.
The Floppy disc drive (S3-M5000) is designed for incorporation within the base unit of the notebook computer. It is a 3 mode disc drive, weighs 280 grams, and handles 3.5" discs.
The base unit (S3-M8000) incorporates a built-in X6 CD-ROM device, "warm docking" capability with the S3 system, 16 MB memory, removable FDD slot, and a built-in 10Base Ethernet connector. It weighs approximately 2.2 pounds and is 11 inches in width.
The CPU daughter board with CPU (S3-M7000), that will be separately shipped, is a board that incorporates a Pentium 100 MHZ/133 CPU, Intel Mobil Triton chip set, 256K byte pipeline burst cache SRAM, and a 240 pin proprietary connector to the S3 system mother board. This daughter board does not incorporate a BIOS chip, and cannot function by itself as a motherboard.
The various subassemblies of the S3 notebook computer, in their imported condition, do not have the essential character of a complete or finished digital processing unit, noting GRI-2 (a) to the Harmonized Tariff Schedule, and also HQ Ruling letters 954411 and 957178. Since the subassemblies are not physically attached to each other and separately boxed, they would be separately classifiable noting Legal Note 2 to Section XVI of the HTS.
The applicable subheading for the Main unit (S3-M1000) and the Base unit (S3-M8000) 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 CPU daughter board, which is separately shipped, will be 8473.30.1000, HTS, which provides for printed circuit assemblies. The rate of duty will be free.
The applicable subheading for the AC adapter (S3-M2000) will be 8504.40.7001, which provides for other power supplies for automatic data processing machines or units thereof of heading 8471, with a power output not exceeding 50W. The rate of duty will be 1.8 percent ad valorem.
The applicable subheading for the Main battery unit (S3-M3000) will be 8507.80.8000, HTS, which provides for other storage batteries. The rate of duty will be 4.4 percent ad valorem.
The applicable subheading for the Keyboard unit (S3-M4000) will be 8537.10.9070, HTS, as other boards, panels, consoles, equipped with two or more apparatus of heading 8535 or 8536, for electric control or the distribution of electricity, for a voltage not exceeding 1,000 V. The rate of duty will be 4.3 percent ad valorem.
The applicable subheading for the Floppy disc drive (S3-M5000) will be 8471.70.4035, HTS, as other flexible 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 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.
Roger J. Silvestri