The tariff classification of Network Attached Storage with a built-in Blue-ray rewriter from South Korea

N054856 March 30, 2009 CLA-2-84:OT:RR:NC:1:120 CATEGORY: Classification TARIFF NO.: 8471.70.9000 Ms. Sarah Cho LG Electronics USA, Inc. 910 Sylvan Ave. Englewood Cliffs, NJ 07632 RE: The tariff classification of Network Attached Storage with a built-in Blue-ray rewriter from South Korea Dear Ms. Cho: In your letter dated March 3, 2009 you requested a tariff classification ruling. The merchandise under consideration is the network storage enclosure for the Network Attached Storage NAS with a built-in Blue-ray rewriter, LG Model N4B1 (N). It will be imported without any hard disk drives installed. It is a Disk Array Frame with doors that allows for continuous storage and back-up. It is a single cabinet that measures 7.48 inches wide x 11.37 inches high x 10.64 inches deep, and has four disk storage bays. It is equipped with its own power supply, a service processor (controller), a RAID (Redundant Array of Independent Disks) management support, limited Linux operating system, cooling fans and features USB 2.0 interface, network print server support, and memory card reader support. The rewriter can burn data onto a disc from computers within a Network. Noting Legal Note 5 C to Chapter 84, this device meets the definition of a “unit” of an ADP machine. The applicable subheading for the NAS with built-in rewriter, LG Model N4B1 (N) will be 8471.70.9000 Harmonized Tariff Schedule of the United States (HTSUS), which provides for "Automatic data processing machines and units thereof…Storage units: Other storage units: Other." The general 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 '