NY H81012

May 31, 2001

CLA-2-84:RR:NC:1:110 H81012

CATEGORY: Classification

TARIFF NO.: 8471.60.2000; 8524.39.4000

Mr. Brian Cochran

Logitech Inc.
6505 Kaiser Drive
Fremont, CA 94555-3615

RE: The tariff classification of a cordless computer keyboard and mouse from China or
Thailand.

Dear Mr. Cochran:

In your letter dated May 2, 2001, on behalf of Logitech you requested a tariff
classification ruling.

The merchandise under consideration is the Logitech Cordless Freedom Navigator

Cordless keyboard and wheel mouse. The Cordless Freedom Navigator is for a personal
computer (PC) and consists of a dual receiver device; cordless battery powered computer
keyboard and mouse. In its imported condition the Cordless Freedom Navigator will be
packaged as a complete kit and put up in sets for retail sale. The complete kit will include the
Logitech Cordless Desktop iTouch multimedia keyboard, Web Wheel mouse, receiver,
batteries, CD-ROM software and literature. The Cordless Desktop iTouch multimedia
keyboard is a standard computer keyboard with a detachable palm rest for improved comfort and
less fatigue. There are four additional programmable Internet Keys that can be customized to
launch programs, web sites or Internet search engines. There are also seven additional
Multimedia Keys that are used for standard CD-player controls for playing music on your PC:
Play/Pause, Stop, Previous Track, Next Track, Mute, Volume Up, and Volume Down. The Web
Wheel mouse is designed in a unique fashion for a comfortable and relaxed position for a wide
range of hand sizes. There are two-buttons and a Scroll Wheel on the mouse that lets you
quickly navigate the Web and control your browser. The Cordless Freedom Navigator
receiver operates on a radio frequency virtually eliminating wires to the keyboard and mouse.
The receiver uses advanced digital radio technology for maximum security and reliability
allowing several cordless devices operating in the same room without problems. The receiver
can be connected to a PC in three ways, directly into a PCs USB port, mouse and keyboard
ports, or to a system with PS/2 ports with the use of an adapter.

The Cordless Freedom Navigator appears to meet the definition of a retail set as per
GRI-3 (b) when shipped as a complete kit and put up in sets for retail sale. With the addition of
programmable keys, the iTouch multimedia keyboard exemplifies the “essential character” of
this set.

Nothing Legal Note 6 to Chapter 85 of the Harmonized Tariff Schedule of the United
States (HTS), “Records, tapes and other media of heading 8523 or 8524 remain classified in
those headings, whether or not they are entered with the apparatus for which they are intended.”
The software in all cases remains separately classified in heading 8524, in accordance with
Chapter 85, Note 6, HTS.

The applicable subheading for the Logitech Cordless Freedom Navigator Cordless
keyboard and wheel mouse will be 8471.60.2000, Harmonized Tariff Schedule of the United
States (HTS), which provides for “Automatic data processing machines and units thereof…Input
or output units…Other: Keyboards.” The rate of duty will be free.

The applicable subheading for the CD-ROM software will be 8524.39.4000, Harmonized Tariff
Schedule of the United States (HTS), which provides for “Records, tapes and other recorded
media for sound or other similarly recorded phenomena…Discs for laser reading systems: Other:
For reproducing representations of instructions, data, sound, and image, recorded in a machine
readable binary form…” The rate of duty will be free.

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 Eileen S. Kaplan at 212-637-7019.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division