The tariff classification of an "Alcatel ASN Optical Amplifier Card ("OAC")" from an unspecified country

NY R01470 March 8, 2005 CLA-2-85:RR:NC:N1:109 R01470 CATEGORY: Classification TARIFF NO.: 8517.50.9000 Mr. Michael E. Roll Pisani & Roll 1875 Century Park East Suite 600 Los Angeles, CA 90067 RE: The tariff classification of an “Alcatel ASN Optical Amplifier Card (“OAC”)” from an unspecified country Dear Mr. Roll: In your letter dated February 11, 2005 you requested a tariff classification ruling on behalf of your client Alcatel Submarine Networks (“ASN”). This ruling concerns the classification of an “Alcatel ASN Optical Amplifier Card (“OAC”).” The descriptive literature submitted states that the “Alcatel ASN Optical Amplifier Card (“OAC”)” is a hybrid of optical (transmission), electronic, and mechanical systems that form part of a submarine telecommunication system for use in transmission of aggregate data (speech & data). The OAC is of an ASN generic design and includes features that allow the configuration of the OAC to suit a given system. The ASN OAC functions within the Alcatel 1696 Metro Span Telecommunication Unit by optimizing the amplification performance of aggregate data transmission. The OAC performs this function irrespective of the number of communication channels being operated or the variances in signal integrity experienced over the communication link and in this way achieves a constant amplification performance based upon the telecommunications system configuration. Typically, the OAC provides up to +17 dBM output power for 32 wavelengths in the C band. Output at +20 dBm can be achieved by adding a further pump. The OAC contains two independent stages: a booster and a preamplifier or 2 boosters or 2 amplifiers. To allow for gain flatness, an optical attenuator is present. In operation, the OAC extends the transmission capacity of the telecommunication system. The applicable subheading for the “Alcatel ASN Optical Amplifier Card (“OAC”)” 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 Hackett at 646-733-3015. Sincerely, Robert B. Swierupski Director, National Commodity Specialist Division