The tariff classification of single line telephones and multi-line telephones from China

NY L88914 December 6, 2005 CLA-2-85:RR:NC:MM:109 L88914 CATEGORY: Classification TARIFF NO.: 8517.19.8070; 8517.19.8080 Mr. Stephen W. Marlow Manager, Regulatory Services FedEx Trade Networks Transport & Brokerage, Inc. 205 West Service Road Champlain, NY 12919 RE: The tariff classification of single line telephones and multi-line telephones from China Dear Mr. Marlow: In your letter dated October 27, 2005, you requested a tariff classification ruling, on behalf of your client Mitel Networks, Inc. This ruling pertains to the classification of five items. They are a Superset 4001, a Superset 4015, a Superset 4025, a Superset 4150, and a 5201 IP Phone. The Superset 4001 is a single line digital business telephone providing basic access to features and functionality of the Mitel® SX-200® and the Mitel SX-2000® Private Branch Exchange (PBX) business telephone systems. The call handling features of the Superset 4001 are speed calling, placing calls on hold, transferring calls, setting up conference calls, voice mail access with message waiting lamp, and seven programmable keys. The Superset 4015 is a multi-line digital display business telephone providing user-programmable access to features and functionality of the Mitel® SX-200® and Mitel® SX-2000® Private Branch Exchange (PBX) business telephone systems. The call handling features of the Superset 4015 are 20-character digital display screen for displaying caller ID, call status, and programming options, on-hook dial, headset jack, superkey programming for access to PBX telephone system features, seven programmable keys with LED indicators, limited automatic call distribution (ACD) functionality, speed calling, placing calls on hold, transferring calls, setting up conferences, and voice mail access with message waiting lamp. The Superset 4025 is multi-line backlit digital display business telephone. It is a handsfree speakerphone with context-sensitive softkeys providing users with access to full features and functionality of Mitel® SX-200® and Mitel® SX-2000® Private Branch Exchange (PBX) business telephone systems. The call handling features of the Superset 4025 are speakerphone, handsfree operation, 20-character backlit display, context-sensitive softkeys for feature-set customization, off-hook call announce, 14 programmable keys with LED indicators, supports Automatic Call Distribution (ACD) agent and supervisor functionality, supports firmware download, on-hook dial, headset jack, superkey programming for access to PBX telephone system features. The Superset 4150 is a multi-line digital touch screen display business telephone. It is a handsfree speakerphone with context-sensitive softkeys providing users sophisticated access to the full features and functionality of the Mitel® SX-200® and the Mitel® SX-2000® Private Branch Exchange (PBX) business telephone systems plus PC connectivity to support TAPI-compliant applications. The call handling features of the Superset 4150 are backlit touch screen display, full duplex handsfree operation, speakerphone, context-sensitive softkeys for feature-set customization, off-hook call announce, 14 programmable keys with LED indicators, supports Automatic Call Distribution (ACD) agent and supervisor functionality, supports firmware download, on-hook dial, headset jack- superkey programming for access to PBX telephone system features, speed calling, placing calls on hold, transferring calls, setting up conference calls, and voice mail access with message waiting lamp. The 5201 IP Phone is a single line Internet Protocol (IP) Phone. It is a basic entry-level IP phone for access to telephony and messaging services. The features of this phone are four function keys; hold, message, transfer/conference or redial, and volume, call hold, call transfer, conference calls, voice mail access with message waiting lamp, ringer volume control, and wall mount capability. The applicable subheading for the Superset 4001 and the 5201 IP Phone will be 8517.19.8070, Harmonized Tariff Schedule of the United States (HTS), which provides for ““Electrical apparatus for line telephony or line telegraphy including telephone sets with cordless handsets…Telephone sets; videophones: Other: Other; Single line: Other: Other.” The rate of duty will be free. The applicable subheading for the Superset 4015, the Superset 4025, and the Superset 4150 will be 8517.19.8080, Harmonized Tariff Schedule of the United States (HTS), which provides for “Electrical apparatus for line telephony or line telegraphy including telephone sets with cordless handsets…Telephone sets; videophones: Other: Other: Multiline (including key, call director and consoles).” The general 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