The tariff classification of an ETC (Ethernet ControllerBoard) assembly from Japan.

NY 804206 November 16, 1994 CLA-2-84:S:N:N1:110 804206 CATEGORY: Classification TARIFF NO.: 8471.99.1500 Mr. Richard H. Abbey Mudge Rose Guthrie Alexander & Ferdon 2121 K Street, N.W. Washington, D.C. 20037 RE: The tariff classification of an ETC (Ethernet Controller Board) assembly from Japan. Dear Mr. Abbey: In your letter dated November 7, 1994, on behalf of General Electric Medical Systems, you requested a tariff classification ruling. The merchandise under consideration involves a "ETC ASSY" that is basically an Ethernet Controller Board that is used with the processor portion of Computed Tomography scanner systems (CT),and Magnetic Resonance Imaging (MRI) systems. The board contains a Motorola 68332 microprocessor, a Hitachi HM53400AZ-7 memory chip (to which operating instructions are loaded from the system disk drive), Hitachi 27C4096 PROMS, and other supporting ICs to allow connection to a 10 Base-T Ethernet network. The board will be separately imported, and when imported will be physically incorporated in the computer of the CT or MRI systems. When a CT or MRI produces an image, it is stored in the systems disk drive of the host computer. If the image is to be studied, analyzed or manipulated at another workstation or on another diagnostic system on the Ethernet network, the image file is transferred from the system disk drive to the Ethernet Controller Board which converts it into a format compatible with and recognized by other systems. Noting Legal Note 5 (B) to Chapter 84 of the HTS, these Ethernet Controller Boards appear to meet the definition of a "unit" of an ADP system. They also effect the interconnection of one central processing unit to other digital processing machines, and thus can be considered to be a control and adapter unit. Please note also HQ Ruling letters 952627, 953330, 955907, and 953623, that ruled on similar merchandise. The applicable subheading for the ETC ASSY will be 8471.99.1500, Harmonized Tariff Schedule of the United States (HTS), which provides for control and 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 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