The tariff classification of a CIENA CN 2100(, CN 2110(, CN 2130( from an unspecified country

NY R00959 November 17, 2004 CLA-2-85:RR:NC:MM:109 R00959 CATEGORY: Classification TARIFF NO.: 8517.50.9000 Mr. Michael John Mastroberti Director of Import/Export Compliance CIENA Corporation 1201 Wintersion Rd C2, 2 East Linthicum, MD 21090-2203 RE: The tariff classification of a CIENA CN 2100(, CN 2110(, CN 2130( from an unspecified country Dear Mr. Mastroberti: In your letter dated October 18, 2004, you requested a tariff classification ruling. This ruling concerns the classification of a CIENA CN 2100(, CN 2110(, and CN 2130(. In your letter you stated that your company‘s products were being rebranded from the CIENA LightHandler PC to the CN 2100, the CIENA LightHandler DC to the CN 2110, and the CIENA LightHandler OA to the CN 2130. As such the items subject to this ruling are being referred to as the CIENA CN 2100, CN 2110, and the CN 2130. The CN 2100(, CN 2110(, and CN 2130( comprise a suite of optical products that enable and facilitate the transport of one or more optical services. They play no role in the generation (i.e., modulation) of optical traffic; rather, they enable the transport of that traffic either by providing WDM mux/demux, in the case of the CN 2100, or in the transmission of WDM signals over longer distances (e.g., >80km), in the case of the CN 2110 and CN 2130 products. The descriptive literature submitted states that the CN 2100( is a scaleable, all-optical, passive multiplexer used to add, drop and express CWDM and DWDM wavelength services. It contains up to three modular passive optical modules each providing a multiplexing function to support a specific application. The CN 2100 supports a wide variety of different passive modules that enable operators to offer a diverse set of services over a broad range of point-to-point, linear add/drop, and ring network topologies. The descriptive literature submitted states that the CN 2110( is an all-passive, dispersion compensator used to extend the reach of DWDM transmission systems. It is housed in a compact, rack-mounting, 1RU enclosure. The transmission reach of the DWDM systems is limited primarily by attenuation (i.e., optical loss) and chromatic dispersion. Loss is dealt with using optical amplifiers like the CN 2100. The effects of chromatic dispersion are handled with the use dispersion compensation. The CN 2110 is designed to mitigate the signal distortion caused by chromatic dispersion. Using field-proven dispersion compensating fiber (DCF), the CN 2110 nullifies the effects of chromatic dispersion. Its negative dispersion slope is engineered to cancel the effects of chromatic dispersion for all C-band wavelengths. The descriptive literature submitted states that the CN 2130( is an optical network element that provides optical amplification and optional DWDM filtering. As a network element, the optical amplifier is provisioned and managed from the native management interfaces or via the LightStack NCS, the companion element management system. WDM filtering is provided by up to two optional LightHandler passive DWDM filters modules, which co-reside in the CN 2130 chassis. The filter modules are selected to address specific network applications. While each of these products is offered separately and can be deployed in third-party WDM systems, as they conform to standard WDM specifications, they have been designed to operate synergistically with each other and other LightStack transport products (e.g. GSLAM, etc.). These synergies provide for optimized physical packaging, thus keeping system footprint, cabling, and engineering to a minimum. The applicable subheading for the CN 2100, CN 2110, and the CN 2130 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