The tariff classification of an "Alcatel ASN Electrical Interface Unit" from an unspecified country

NY L80614 November 22, 2004 CLA-2-85:RR:NC:MM:109 L80614 CATEGORY: Classification TARIFF NO.: 8517.50.9000 Mr. Robert Pisani, Esq. Pisani & Roll 1717 K Street NW Suite 600 Washington, DC 20036 RE: The tariff classification of an “Alcatel ASN Electrical Interface Unit” from an unspecified country Dear Mr. Pisani: In your letter dated October 12, 2004, you requested a tariff classification ruling on behalf of your client Alcatel Submarine Networks. This ruling concerns the classification of “Alcatel ASN Electrical Interface Unit.” The descriptive literature submitted states that the “Alcatel ASN Electrical Interface Unit” is a replaceable unit in Alcatel’s Power Feeding Equipment (PFE), a hybrid of optical, electronic and mechanical system that forms part of a submarine telecommunication system for use in transmission of aggregate data. The “Alcatel ASN Electrical Interface Unit” acts as an interface between electrical units such as relays, and the micro unit and the PFE’s main processor. The unit is 20mm by 260mm by 190mm. Your letter suggested HTS 8517.50.5000, which provides for “Electrical apparatus for line telephony or line telegraphy…Other apparatus, for carrier-current line systems or for digital line systems: Other: Telephonic.” With respect to this subheading, “telephonic” apparatus involves the transmission of speech (voice) or other sounds between two points. However, the “Alcatel ASN Electrical Interface Unit” is used in the transmission of aggregate data, in addition to the transmission of speech or other sounds. As such, it is considered “telegraphic” apparatus, which is provided for within subheading 8517.50.90, as “telegraphic” apparatus. The applicable subheading for the an “Alcatel ASN Electrical Interface Unit” will be 8517.50.9000, Harmonized Tariff Schedule of the United States (HTS), which provides for “Other apparatus, for carrier-current line systems or for digital line systems: Other: Telegraphic: Other.” 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 Linda M. Hackett at 646-733-3015. Sincerely, Robert B. Swierupski Director, National Commodity Specialist Division