The tariff classification of a NetRunner Integration Router(LAN/WAN) from Malaysia

NY 813194 August 2, 1995 CLA-2-84:S:N:N1:110 813194 CATEGORY: Classification TARIFF NO.: 8471.99.1500 Mr. Dennis Heck Tower Group International, Inc. 2400 Marine Avenue Redondo Beach, CA 90278-1103 RE: The tariff classification of a NetRunner Integration Router (LAN/WAN) from Malaysia Dear Mr. Heck: In your letter dated July 28, 1995, on behalf of Micom Communications Corp., you requested a tariff classification ruling. The merchandise under consideration involves a NetRunner 75E Integration Router which is basically a free standing unit that allows for multiprotocol transmissions to be sent across wide area network (WAN) lines. This device is a high-performance IP/IPX router, with hardware data compression and central point of control. Voice digitization and compression is performed by using 20 MIPS digital signal processors (DSP) in order to reduce WAN bandwidth requirements. This multiprotocol router offers the capability to integrate data and voice/fax traffic, while minimizing overall network administrative burdens. Each NetRunner Integration Router includes from two to five data ports for integrating legacy synchronous data (e.g. SNA, X.25, DDCMP) and legacy async data (e.g. DEC, HP, Unix) along with remote LAN traffic. The board of this unit contains a Z80- Zilog microprocessor, 1.5MB of flash EPROM for program memory, BIOS PROM, and has I/O capability. This device is approximately 17 inches in width, 4.4 inches in height, and 11.8 inches in depth, and weighs 13 pounds. Noting Legal Note 5 (B) to Chapter 84, this router would appear to meet the definition of a "unit" of an ADP system. They control and process information exchange within the framework of a network, and are used to interconnect the CPU to other units or ADP machines, thereby serving "control" and "adaptor" functions. The applicable subheading for the NetRunner 75E Integration Router will be 8471.99.1500, Harmonized Tariff Schedule of the United States (HTS), which provides for control or adaptor units. The rate of duty will be free. 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