The tariff classification of uninterruptible power supplies from TaiwanDear Ms. Trout:In your letter dated April 23, 1999, on behalf of your client, Para Systems, Inc. of Carrollton, Texas, you requested a tariff classification ruling.The merchandise is described in your letter as uninterruptible power supply systems. The merchandise is identified as the Pro Series and consists of the following models: Model Pro320 & 320i (capacity of 320VA and 208W)Model Pro520 & 520i (capacity of 520VA and 338W)Model Pro700 & 700i (capacity of 700VA and 455W)Model Pro1400 & 1400i (capacity of 1400VA and 910W)These models are for the U.S. market and run on 120, 208 and 240 volts. For the international markets (models designated with an ), the voltage would be 220, 230 and 240 volts. These systems offer protection from power surges, total power outages, voltage spikes, and other power problems. Your literature indicates that applications for these units would include telephone key systems, file

PD E81237 May 21, 1999 CLA-2-85:P-OFO- B07 E81237 CATEGORY: Classification TARIFF NO.: 8504.40.8500 Ms. Dana L. Trout Vice President, Imports Trans-Trade, Inc. P.O. Box 612369 DFW Airport, TX 75261 RE: The tariff classification of uninterruptible power supplies from Taiwan Dear Ms. Trout: In your letter dated April 23, 1999, on behalf of your client, Para Systems, Inc. of Carrollton, Texas, you requested a tariff classification ruling. The merchandise is described in your letter as uninterruptible power supply systems. The merchandise is identified as the Pro Series and consists of the following models: Model Pro320 & 320i (capacity of 320VA and 208W) Model Pro520 & 520i (capacity of 520VA and 338W) Model Pro700 & 700i (capacity of 700VA and 455W) Model Pro1400 & 1400i (capacity of 1400VA and 910W) These models are for the U.S. market and run on 120, 208 and 240 volts. For the international markets (models designated with an ), the voltage would be 220, 230 and 240 volts. These systems offer protection from power surges, total power outages, voltage spikes, and other power problems. Your literature indicates that applications for these units would include telephone key systems, file servers, network devices and graphic workstations. Based upon GRI 6 and GRI 3(c), these goods are classified in the subheading which occurs last in numerical order. The applicable subheading for these uninterruptible power supplies will be 8504.40.8500, Harmonized Tariff Schedule of the United States (HTS), which provides for converters: [f]or telecommunication apparatus. 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, Ian C. Sang Port Director Phoenix