NY 816508: The tariff classification of disk drives and a controller from Japan.

Native CBP ruling rendition. Applicability is fact-specific; modification/revocation relationships and original publisher date are retained. Publisher sentinel year0001 means unknown date, not a historical legal adoption.

	NY 816508

                            November 9, 1995


CLA-2-84:R:N1:110 816508  

CATEGORY:  Classification

TARIFF NO.: 8471.93.4050; 8471.99.15000  

Mr. Tom Duffy
Fujitsu America, Inc.
1741 Junction Avenue
San Jose, CA 95112-1010

RE:	The tariff classification of disk drives and a controller from Japan.

Dear Mr. Duffy:

	In your letter dated November 6, 1995, you requested a tariff classification ruling.

	The merchandise under consideration involves an external disk drive and controller that makes up a storage system.  The base disk drive unit model number will be M2672A and the base controller unit model number will be M1027A.

     The disk drive will be imported complete, with a cabinet, that will incorporate disks under 21 cm, and an attached external power supply.  The number of card drives incorporated within the drive unit will differ with the shipments.  Each drive and controller are separate components, and are imported for inventory stock.   Each controller and disk drive has their separate power supply, and are not physically connected to each other until they get to the customer site.

     The dimension of the external disk drive is as follows: 550mm in width; 750mm in depth; and 1800mm in height.  It is bolted to  the controller after importation and connected with a ribbon cable.  Noting Legal Note 5 (B) to Chapter 84, this disk drive would meet the definition of a "unit" of an ADP system.

     The dimension of the controller is as follows: 665mm in width; 750mm in  depth; and 1800mm in  height.  The connection from the M1027A controller to the CPU is  by fiber optic cable.  As with the disk drive, this controller meets the definition of a "unit" of an ADP system.     
   
	
	The applicable subheading for the M2672A disk drive will be 8471.93.4050, Harmonized Tariff Schedule of the United States (HTS), which provides for other magnetic disk drive units.  The rate of duty will be 3 percent ad valorem.   

     The applicable subheading for the M1027A controller will  be 8471.99.1500, HTS, which provides for control or adapter units.  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 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.



								Sincerely,



								Roger J. Silvestri
								Director
								National Commodity
								Specialist Division