The tariff classification of a JBOD and a RAID controller module from Mexico

N028175 June 11, 2008 CLA-2-84:OT:RR:E:NC:1:120 CATEGORY: Classification TARIFF NO.: 8471.80.1000 Ms. Lisa Crosby Sidley Austin LLP 1501 K St NW Washington DC 20005 RE: The tariff classification of a JBOD and a RAID controller module from Mexico Dear Ms. Crosby: In your letter dated May 12, 2008 you requested a tariff classification ruling on behalf of LSI Corporation. The merchandise under consideration involves the JBOD and RAID controller modules used in an array storage subsystem. The subsystem uses an enhanced Redundant Array of Inexpensive Disks ("RAID") design, which allows for continuous storage, backup and maintenance of the subsystem without having to take the system down. The JBOD is used to monitor the subsystem’s running condition and analyze its faults. Both the JBOD and RAID controller modules are chassis designed with a “disk storage unit”, which has empty hard drive canisters in which magnetic disk drives will be placed after importation. The JBOD has a power supply unit with an ESM, whereas the RAID controller module has the power supply unit with a controller. The ESM is a canisterized board that enables communication with the CPU of a computer. Via the ESM, the JBOD reports status from the hard disk drives back to the CPU through the RAID controller or host adaptor board in the host computer. The controller unit performs as an interface between the subsystem's storage unit (hard disk drives) and the CPU. Its function is to connect with the data source and send data to various hard disk drives in the subsystem. You requested classification under subheading 8471.70 as unfinished storage units, or under subheading 8473.30 as Parts and accessories of the machines of heading 8471: Other. Without memory or the hard disk drives, they do not have the essential character of a storage unit as requested. The JBOD and a RAID controller module meet the definition of an automatic data processing (ADP) unit, and are performing the function of an interface between the CPU and the subsystem’s storage units to perform data transfer functions. They are specifically provided for as ADP control or adapter units. The applicable subheading for the JBOD and a RAID controller module will be 8471.80.1000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "Automatic data processing machines and units thereof; magnetic or optical readers, machines for transcribing data onto data media in coded form and machines for processing such data, not elsewhere specified or included: Other units of automatic data processing machines: Control or adapter units." The rate of duty will be free. Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/. This ruling is being issued under the provisions of Part 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 Denise Faingar at 646-733-3010. Sincerely, Robert B. Swierupski Director, National Commodity Specialist Division