The tariff classification of CIENA’S CN4200, CN4200 MC, and CN4200 RS platforms from various countries

N038388 September 26, 2008 CLA-2-85:OT:RR:E:NC:N1:109 CATEGORY: Classification TARIFF NO.: 8517.62.0050 Mr. Marcus Gillings, Compliance Analyst CIENA Corporation 920 Elkridge Landing Road 521 McCormick Drive Linthicum, MD 21090-2917 RE: The tariff classification of CIENA’S CN4200, CN4200 MC, and CN4200 RS platforms from various countries Dear Mr. Gillings: In your letter dated September 15, 2008, you requested a tariff classification ruling. This ruling concerns the classification of CIENA’S CN4200, CN4200 MC, and CN4200 RS platforms that provide a service-enabled transport layer, allowing network operators to manage and provision individual services with packet-like ease and flexibility without sacrificing the carrier-class performance, management features, and reliability of SONET/SDH. In general, the CN4200, CN4200 MC, and CN4200 RS platforms are networking equipment. The CN 4200 FlexSelect Advanced Services Platform Family redefines the term “multiservice” for the telecommunications industry, creating a new paradigm for network operators considering transport technology and applications. With its unique FlexiPort technology and advanced multiplexing capabilities, CN 4200 goes far beyond the functionality of traditional metropolitan Wavelength Division Multiplexing (WDM) systems and SONET/SDH Multiservice Provisioning Platforms (MSPPs). The CN4200 FlexSelect Advanced Services Platform Family is a multiservice provisioning, aggregation, and transport solution that can converge virtually any service from 10 MB/s Ethernet to 10G Ethernet, SONET/SDH, storage and video with Service Level Agreements (SLAs). The platform is designed specifically to support worldwide migration from Time Division Multiplexing (TDM) to IP services by providing unprecedented service flexibility with software-programmable FlexiPort line modules that deliver any service, at any rate, on any port. The CN 4200 model features the original four-slot CN 4200 chassis. It is suitable for any location that requires moderate service density for access service aggregation, cross-connect, and add/drop multiplexing. It has four fully interconnected card slots to support switching and grooming and a one card slot for optical fibers and amplifiers. The CN 4200 MC model features the smaller, two-slot CN 4200 MC chassis. It is designed for locations with limited service density for access service aggregation, cross-connect, and add/drop multiplexing. CN 4200 MC also provides the ideal solution for sites with highly-focused requirements such as access nodes, In-Line Amplifiers (ILAs), and repeater nodes. The CN 4200 RS model features a chassis that is designed for high-density sites that require large access service aggregation, cross-connect, add/drop multiplexing, automatic power balancing, and/or multi-degree ROADM functionality. The CN 4200 RS platform is designed to operate in the central office (-48V DC) with increased capacity equivalent to four CN 4200 chassis. The applicable subheading for the CIENA’S CN4200, CN4200 MC, and CN 4200 RS platforms will be 8517.62.0050, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Machines for the reception, conversion and transmission or regeneration of voice, images or other data, including switching and routing apparatus: Other.” The 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 Linda M. Hackett at 646-733-3015. Sincerely, Robert B. Swierupski Director National Commodity Specialist Division