The tariff classification of analog and digital modem adaptors from China

NY B80467 January 13, 1997 CLA-2-85:RR:NC:MM:109 B80467 CATEGORY: Classification TARIFF NO.: 8517.90.4400, 8517.90.6600 Mr. Dick Stanhope Traffic and Customs Mgr. Microcom, Inc. 500 River Ridge Drive Norwood, MA 02062-5028 RE: The tariff classification of analog and digital modem adaptors from China Dear Mr. Stanhope: In your letter dated December 9, 1996, you requested a tariff classification ruling. The merchandise is described in your letter and in the attached literature as analog and digital modem adaptors. Additional information and clarification was obtained on January 9, 1997, in a telephone conference with Darryl Peterson, Design Engineer, Microcom. These adaptors are printed circuit boards (PCBs) that attach to the back plane of the ISPorte Managed Modem Chassis. The ISPorte offers up to 64 data/fax modems in a compact 19" rackmount design. The analog adaptor is used for connecting each modem to a standard two wire analogue telephone line. It converts from four wires to two. The PCBs are populated with isolation transformers, resistors, capacitors, and connectors (RJ11, RJ45). They do not contain any active components within the meaning of Section XVI Additional U.S. Note 1, and are therefore, not considered a "printed circuit assembly" for the purposes of that section. The digital adaptor is used for connecting to digital T1 type lines. They contain active components which convert the analog modem signals into a digital signal for transmission over a T1 line. The applicable subheading for the analog modem adaptors will be 8517.90.6600, Harmonized Tariff Schedule of the United States (HTS), which provides for "[e]lectrical apparatus for...line telegraphy...[p]arts: [o]ther: [o]ther: [f]or telegraphic apparatus." The rate of duty will be 4.7%. The applicable subheading for the digital modem adaptors will be 8517.90.4400, Harmonized Tariff Schedule of the United States (HTS), which provides for "[e]lectrical apparatus for...line telegraphy...[p]arts: [o]ther: [p]rinted circuit assemblies: [f]or telegraphic apparatus." The rate of duty will be 4.7%. 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 212-466-5673. Sincerely, Robert B. Swierupski Chief, Metals & Machinery Branch National Commodity Specialist Division