The tariff classification of printer adapters from Canada.

NY 884519 April 5, 1993 CLA-2-84:S:N1:110: 884519 CATEGORY: Classification TARIFF NO.: 8471.99.1500; 8524.90.4080 Mr. Steve Sanders Fritz Companies, Inc. P.O. Drawer "G" Blaine, Washington 98230 RE: The tariff classification of printer adapters from Canada. Dear Mr. Sanders: In your letter dated March 29, 1993, on behalf of Microplex Systems Ltd., you requested a tariff classification ruling. The merchandise under consideration involves the model numbers M200 and M201 "Microplex TCP/IP Printer Adapters" which are used to interface printers in a computer network system. The M200 and M201 TCP/IP printer adapters enables users to locate printers, and other output devices anywhere on their Ethernet LANs eliminating the need to attach them directly to a host system. Both models incorporate a 16-bit processor with DMA channel to provide faster throughput than direct host computer printing. These Microplex printer adapters incorporate an IBM parallel port that supports data rates in excess of 50,000 characters per second. A user can access up to three printers per adapter through the network, thus freeing up host ports for other purposes. Noting Legal Note 5(B) to Chapter 84 of the HTS, and recent Headquarter's Ruling 952659 of October 7, 1992, these two printer adapters would meet the definition of a "unit" of an automatic data processing machine. The principal function of these printer adapters appears to be for the interconnection of the central processing unit to input-output devices within an ADP system thereby providing "adaption" functions. It is noted that these printer adapters are marketed in a "unit" box that includes user manuals, installation software on diskettes, parallel printer cable, and an AC/AC adapter (transformer). Noting GRI-3(a), the merchandise would appear to be a set put up for retail sale, with the "essential character" of the set being the printer adapter. The applicable subheading for the model numbers M200 and M201 "Microplex TCP/IP Printer Adapters" will be 8471.99.1500, Harmonized Tariff Schedule of the United States (HTS), which provides for other control or adapter units. The duty rate will be free. Noting Legal Note 6 to Chapter 85, the software diskettes would be separately classifiable under 8524.90.4080, Harmonized Tariff Schedule of the United States (HTS), which provides for other recorded media. The rate of duty will be 9.7 cents per square meter of recording surface. 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