NY 863652: The tariff classification of an Electronic Card File from Hong Kong and China.

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 863652
                                May 29, 1991



CLA-2-84:S:N:N1:110 863652  

CATEGORY:  Classification

TARIFF NO.: 8472.90.8000  

Mr. Michael R. Doram
Politis, Pollack & Doram
3255 Wilshire Blvd., Suite 1688
Los Angeles, Ca. 90045

RE:  The tariff classification of an Electronic Card File from   
  Hong Kong and China.

Dear Mr. Doram:

     In your letter dated May 16, 1991, on behalf of Tele-Art
Marketing, Ltd., you requested a tariff classification ruling.   
     
     The merchandise under consideration is an Electronic Card
Filing Machine.  The three models in question have the commercial
designation of the 24K, 32K, and the 64K Electrodex Basic.  The
24K Electrodex Basic is a battery powered free standing machine,
which contains a LCD display screen, a keypad used to enter and
access stored data, self-contained internal ROM programming, and
RAM data storage memory, and a knurled knob called the "Spin-
Dial" which can be manually turned to rapidly view files.  These
are office machines which have a wide base for placement on a
desk and generally resemble a typewriter in appearance.  

     The Electrodex Basic also contains a Time Based Reminder
Note Schedule System, a full function calculator, time and date
display, and an auto dialing feature which could be connected to
a single telephone line to permit speed dialing of any telephone
number which has been stored in the memory.  The Electrodex Basic
Electronic Card File operates entirely independently from any
telephone lines.  The user may elect not to connect the machine
to the telephone.  

      The Electrodex Basic is a composite article, and the
"essential character" is imparted by the electronic storage and
retrieval function, particularly the display.  Buying a telephone
dialer would be less expensive if the auto dialer function was of
major importance.  Noting GRI 3(b), an article consisting of
different components  which cannot be classified by reference to
3(a), shall be classified as if they consisted of the component
which gives them their "essential character".  In this instance,
the "essential character " of the Electrodex Basic is imparted by
their storage and retrieval function of previously stored and
filed information, such as addresses, phone numbers, and
reference information.

     The applicable subheading for the models 24K, 32K, and 64K
Electrodex Basic Card File will be 8472.90.8000, Harmonized
Tariff Schedule of the United States (HTS), which provides for
other office machines.  The rate of duty will be 3.7 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