Mr. Peter T. Middleton, Esquire
Middleton & Shrull
44 Mall Road, Suite 208
Burlington, MA. 01803-4530
RE: The tariff classification of notebook computer components from Japan.
Dear Mr. Middleton:
In your letter dated January 2, 1997, on behalf of Packard Bell NEC Sales Co., you requested a tariff classification ruling.
The merchandise under consideration involves components of a model number RT5, notebook computer which is also known as the VERSA 2600 Series notebook computer.
The RT5 sub-assembly base unit will be assembled in Japan. This imported sub-assembly will include all components except for the lithium-ion or NiMH battery pack, AC adapter, keyboard, hard disc drive, and the CPU daughter board with the microprocessor. The keyboard and the daughter board with the microprocessor will be imported separately. The hard disc drive will be acquired in the United States. The battery pack and a separate AC adapter will be produced abroad and shipped into the United States apart form the other components.
The keyboard does not contain any of the electronics necessary for functioning, all of which is assembled within the main unit. The rechargeable battery pack will be either a NiMH 8-cell 1.2V each, or a Lithium-ion 6-cell 1.6V each configuration. The AC adapter has a 100V-240V, 50/80Hz input, and 15V 1700mA or 18V 1000mA output. The daughter board contains an Intel TCP package. It does not contain a BIOS IC which is on the motherboard assembly.
The subassembly of the RT5 VERSA 2600 notebook computer, in its imported condition, does 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. The other components of the VERSA 2600 are shipped separately, and would be separately classifiable, noting Legal Note 2 to Section XVI of the HTS.
The applicable subheading for the RT5 VERSA 2600 sub-assembly base unit 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 keyboard, without its electronics, 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 3.7 percent ad valorem.
The applicable subheading for the AC adapter will be 8504.40.7001, HTS, 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 1.2 percent ad valorem.
The applicable subheading for the Lithium-ion battery pack will be 8507.80.8000, HTS, which provides for other storage batteries. The rate of duty will be 4.1 percent ad valorem.
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.
Robert B. Swiersupski
Chief, Metals & Machinery Branch