HQ 083188: "Magnet Picturebase" image data processing system consistingof the following components: processor unit, image datacompressor unit, disk controller, Winchester drive units, tapearchive unit, visual display CRT unit(s) (VDU), dot matrixprinter unit and keyboard(s).

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.

                            HQ 083188


                        February 22, 1990


CLA-2 CO:R:C:G  083188 MBR

CATEGORY:,  Classification

TARIFF NO.:,  8471.91.00, 8471.99.15, 8471.93.20, 8471.93.60,
8471.92.65, 8471.92.40, 8471.92.20

Mrs. Nadine D. Silsbee
Brain A. Hill & Company, Inc.
Hill Cargo Facility
Logan Airport
East Boston, Massachusetts 02128

RE:  "Magnet Picturebase" image data processing system consisting
of the following components:  processor unit, image data
compressor unit, disk controller, Winchester drive units, tape
archive unit, visual display CRT unit(s) (VDU), dot matrix
printer unit and keyboard(s).

Dear Mrs. Silsbee:

  This is in reply to your letter of August 10, 1988, on behalf
of Crosfield Hastech, Inc., requesting classification of the
Magnet Picturebase data processing system, under the Harmonized
Tariff Schedule of the United States Annotated (HTSUSA).

FACTS:

  The Magnet Picturebase system is a management information
system that allows for networking capability, provides on-line
archiving of compressed computer scanned images, which are stored
on two or more (up to six) 340 megabyte winchester disk drives,
has the ability to track jobs through the system and can gather
productivity data.  The system essentially consists of the
following components: processor unit, image data compressor
(processor) unit, disk controller, Winchester drive units, tape
archive unit, visual display CRT unit(s) (VDU), dot matrix
printer unit and a keyboard for each VDU.

ISSUE:

  What are the classifications of the Magnet Picturebase data
processing system under the Harmonized Tariff Schedule of the
United States Annotated (HTSUSA)?



LAW AND ANALYSIS:

  The General Rules of Interpretation (GRI's) to the HTSUSA
govern the classification of goods in the tariff schedule.  GRI 1
states, in pertinent part:

     ...classification shall be determined according to the terms
     of the headings and any relative section or chapter notes...

  The processor unit meets the definition of a digital processing
unit as defined in Chapter 84, Legal Note 5(A)(a), which states:

     (A) For purposes of heading 8471, the expression "automatic
     data processing machines" means:

          (a) Digital machines, capable of (1) storing the
          processing program or programs and at least the data
          immediately necessary for execution of the program; (2)
          being freely programmed in accordance with the
          requirements of the user; (3) performing arithmetical
          computations specified by the user; and, (4)
          executing, without human intervention, a processing
          program which requires them to modify their execution,
          by logical decision during the processing run;

  Therefore, the processor unit is classifiable under subheading
8471.91.00, HTSUSA, which provides for: "[d]igital processing
units, whether or not entered with the rest of the system, which
may contain in the same housing one or more of the following
types of units: storage units, input units, output units."

  The image data compressor "compresses" (processes) image data
in a ratio of 6:1 in order to increase the system's storage
capabilities.  Therefore, the data compressor is appropriately
classifiable under subheading 8471.91.00, HTSUSA, which provides
for:  "[d]igital processing units, whether or not entered with
the rest of the system...."

  The disk controller is provided for specifically under
subheading 8471.99.15, HTSUSA, which provides for: "[o]ther
controller or adaptor units."

  The winchester disk drive cabinet is a free-standing peripheral
storage unit that houses up to three "trays," each containing two
340 Mbyte magnetic disk drives (i.e. from two up to six disk
drives).  The winchester disk diameter is aproximately 8" (i.e.,
over 21 cm in diameter).

  Classification is therefore appropriate under subheading
8471.93.20, HTSUSA, when these large capacity disk drives are
imported together as a unit.  Subheading 8471.93.20, HTSUSA,
provides for: "[s]torage units, whether or not entered with the
rest of the system: [m]agnetic disk drive units: [f]or a disk of
a diameter exceeding 21 cm: [o]ther."

   The optional tape archive free standing peripheral unit,
housed in its own cabinet, is classifiable under subheading
8471.93.60, HTSUSA, which provides for: "[s]torage units, whether
or not entered with the rest of the system: [o]ther storage
units: [o]ther."

  The dot matrix printer is a complete output unit, that is
assembled and includes at least the media transport, control and
print mechanism.  The printer is therefore classifiable under
subheading 8471.92.65, HTSUSA.

  The visual display(s) (up to 5 VDU's can be attached to the
system) are free-standing output devices that incorporate a
cathode-ray tube.  Therefore, the VDU's are classifiable under
subheading 8471.92.40, HTSUSA, which provides for: "[i]nput or
output units...: [o]ther: [d]isplay units: [o]ther, with cathode-
ray tube (CRT)."

  The keyboard is a free-standing input device, dedicated for
use with the digital processing machine of this system.
Classification is thus appropriate under subheading 8471.92.20,
HTSUSA, which provides for: "[i]nput or output units...: [o]ther:
[k]eyboards."

HOLDING:

  The processor unit is classifiable under subheading
8471.91.00, HTSUSA, which provides for: "[d]igital processing
units, whether or not entered with the rest of the system, which
may contain in the same housing one or more of the following
types of units: storage units, input units, output units."  The
rate of duty is 3.9% ad valorem.

The data compressor (processor) is appropriately classifiable
under subheading 8471.91.00, HTSUSA, which provides for:
"[d]igital processing units, whether or not entered with the rest
of the system..."  The rate of duty is 3.9% ad valorem.

  The disk controller is classifiable under subheading
8471.99.15, HTSUSA, which provides for: "[o]ther controller or
adaptor units."  The rate of duty is free.

  Classification for the winchester disk drives, imported
together as a unit, is appropriate under subheading 8471.93.20,
HTSUSA.  Subheading 8471.93.20, HTSUSA, provides for: "[s]torage
units, whether or not entered with the rest of the system:
[m]agnetic disk drive units: [f]or a disk of a diameter exceeding
21 cm: [o]ther."  The rate of duty is 3.7% ad valorem.

   The optional tape archive free standing peripheral unit,
housed in its own cabinet, is classifiable under subheading
8471.93.60, HTSUSA, which provides for: "[s]torage units, whether
or not entered with the rest of the system: [o]ther storage
units: [o]ther."  The rate of duty is 3.7% ad valorem.

  The dot matrix printer is a complete output unit, that is
assembled and includes at least the media transport, control and
print mechanism.  The printer is therefore classifiable under
subheading 8471.92.65, HTSUSA.  The rate of duty is 3.7% ad
valorem.

  The visual displays are a free-standing output device that
incorporate a CRT.  Therefore, the VDU's are classifiable under
subheading 8471.92.40, HTSUSA, which provides for: "[i]nput or
output units...: [o]ther: [d]isplay units: [o]ther, with cathode-
ray tube (CRT)."  The rate of duty is 3.7% ad valorem.

  The keyboard is a free-standing input device, dedicated for use
with the digital processing machine of this system.
Classification is thus appropriate under subheading 8471.92.20,
HTSUSA, which provides for: "[i]nput or output units...: [o]ther:
[k]eyboards."  The rate of duty is free.

                              Sincerely,




                              John Durant, Director
                              Commercial Rulings Division