The tariff classification of an "Alcatel 1354 SN Network Manager for Telecommunication Equipment" from an unspecified country

NY L86669 August 17, 2005 CLA-2-85:RR:NC:MM:109 L86669 CATEGORY: Classification TARIFF NO.: 8517.50.9000 Mr. Michael E. Roll Pisani & Roll 1717 K Street NW Suite 600 Washington, DC 20036 RE: The tariff classification of an “Alcatel 1354 SN Network Manager for Telecommunication Equipment” from an unspecified country Dear Mr. Roll: In your letter dated August 3, 2005, you requested a tariff classification ruling on behalf of your client Alcatel Submarine Networks. This ruling concerns the classification of an “Alcatel 1354 SN Network Manager for Telecommunication Equipment.” The descriptive literature submitted states that the “Alcatel 1354 SN Network Manager for Telecommunication Equipment” is a hardware product, which, at the time of importation, has software loaded (imbedded) onto it. The Alcatel 1354 SN is comprised of software (telecommunication information technology) installed onto a computer hardware platform and is developed specifically to manage Alcatel submerged telecommunication equipment and the telecommunication systems in which they operate. The Alcatel 1354 SN is of an Alcatel generic design and includes features that allow configuration of the Alcatel 1354 SN to suit a given Alcatel telecommunication system requirement. The Alcatel 1354 SN application supports the functions of the Submarine Network Telecommunication Management Layer, providing end-to-end configuration and monitoring of WDM (Wavelength Division Multiplexer) transmission (optical) paths. The 1354 SN runs on a platform, which can be scaled to suit the telecommunication network size. The applicable subheading for the “Alcatel 1354 SN Network Manager for Telecommunication Equipment” 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