NY 849966
Aug 8, 1989

CLA-2-85:S:N:N1:109 849966

CATEGORY: Classification

TARIFF NO.: 8517.82.0080

Mr. Matthew Chang
C. Itoh & Company (America) Inc.
335 Madison Avenue
New York, N.Y. 10017

RE: The tariff classification of telegraphic apparatus
(pentelephone) from Japan.

Dear Mr. Chang:

In your letter dated February 26,1990, you requested a
tariff classification ruling.

Your lettrer describes the "pentelephone," identified in your letter as model TW 100), as a "telewriting" terminal with a facsimile machine. It consists of a telephone hooked up to to an LCD terminal, which, when connected telephonically to another such terminal, allows the user to exchange written material simultaneously by writing with a pen on the LCD. The written image appears simultaneously on both screens. It also contains a facsimile function which permits documents to appear simultaneously on both screens. The telephone unit is built into the entire device. The principal function of the device appears to be the transmission of data between two points using a line connection.

The applicable subheading for the "pentelephone" will be 8517.82.0080, Harmonized Tariff Schedule of the United States (HTS), which provides for "[o]ther telegraphic apparatus." The rate of duty will be 4.7 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