CLA-2-84:S:N:N1:105 875496
Mr. Robert S. Kirschenbaum
Kroy Inc.
P.O. Box C-12279
Scottsdale, AZ 85267-2279
RE: The tariff classification of parts for the Duratype 240 SE
Digital Lettering System from Singapore and Japan
Dear Mr. Kirschenbaum:
In your letter dated June 12, 1992 you requested a tariff
classification ruling.
The four parts you will import are: a mother printed circuit
board (pcb) on which numerous electronic components are mounted,
the primary component being a microprocessor which controls and
coordinates all functions of the machine; a memory printed
circuit board which provides power and additional font data to
the mother pcb for user variation of typestyles; a keyboard
assembly arranged in either the Universal QWERTY configuration or
the French AZERTY one. Like a computer or typewriter one, the
Duratype 240 SE keyboard is used to input alpha-numeric
information; and a felt washer, which provides the desired
friction in a slip clutch assembly, its drag in its installed
configuration controlling the ribbon rewind. The washer is a
product of Singapore; the other three of Japan.
You advocate classification of all four parts in subheading
8442, where, in ruling 873671, we held the complete Duratype 240
SE to be classifiable. The classification of machinery parts,
however, is controlled by the Section XVI Notes (copy included).
Section XVI Note 1(e) excludes articles of textile material.
Section XVI Note 2 governs the classification of parts not
excluded by Note 1.
Since the three parts other than the washer are not goods
included in any of the headings of Chapter 84 and 85, and are
suitable for use solely with the Duratype 240 SE, the applicable
subheading for them will be 8442.40.0000, Harmonized Tariff
Schedule of the United States (HTS), which provides for other
parts of machinery, apparatus and equipment for typesetting.
This provision is free of duty.
The applicable subheading for the felt washer will be
5911.90.0000, which provides for other textile products and
articles, for technical uses. The rate of duty will be 7.5
percent ad valorem.
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