The tariff classification of an InfraStruXure( Manager.

NY L89894 February 1, 2006 CLA-2-84:RR:NC:1:110 L89894 CATEGORY: Classification TARIFF NO.: 8471.80.9000 Mr. Jon Runk American Power Conversion P.O. Box 278 132 Fairgrounds Road West Kingston, RI 02892 RE: The tariff classification of an InfraStruXure( Manager. Dear Mr. Runk: In your letter dated January 6, 2006 you requested a tariff classification ruling. The merchandise under consideration is the American Power Conversion Corporation (APC) InfraStruXure( Manager Appliance, sku # AP92200. A sample was provided with your request and will be returned to you. The APC InfraStruXure( Manager is a rack-mounted unit used to manage multiple APC network devices necessary for managing an entire networks critical physical infrastructure. This unit provides a network administrator the ability to individually control Critical Power, Cooling Racks and Physical Structure, Security and Fire Protection, Cabling, Management Systems and Network Servers from a single console or by integrating the InfraStruXure( Manager into a preferred management system. The APC InfraStruXure( Manager is a self-contained unit with an internal hard disk drive (HDD) and measures approximately 17” wide by 6¾” deep and is 1¾” high. The face of this unit features two LED (Light Emitting Diodes), two USB (Universal Serial Bus) ports, two LAN (Local Area Network) Ethernet ports, RS-485 port for integration with a Building Management System, RS-232 port, VGA monitor and PS/2 Keyboard ports. The APC InfraStruXure( Manager does not have any control features over any of the APC devices it manages. It provides the user with a central management server to manage APC devices and APC or customer supplied hubs and/or switches. The APC InfraStruXure( Manager appears to meet the definition of a “unit” of an ADP system under Legal Note 5 (B) to Chapter 84 of the Harmonized Tariff Schedule of the United States (HTSUS). The applicable subheading for the APC InfraStruXure( Manager will be 8471.80.9000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Automatic data processing machines and units thereof… Other units of automatic data processing machines: Other: Other.” The general rate of duty will be free. Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/. 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 Thomas Campanelli at 646-733-3016. Sincerely, Robert B. Swierupski Director, National Commodity Specialist Division