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NY 845200


September 15, 1989

CLA-2-85:S:N:N1:109 845200

CATEGORY: CLASSIFICATION

TARIFF NO.: 8517.90.3000, 8536.50.00, 8544.41.0000

Mr. Anthony R. Pranses
Rudolph Miles & Sons, Inc.
4950 Gateway East
P.O. Box 144
El Paso, Texas 79942

RE: The tariff classification of telephone parts from Mexico.

Dear Mr. Pranses:

In your letter dated September 1, 1989, you requested a tariff classification ruling on behalf of Comdial Corporation, Charlottesville, VA..

Your letter describes the telephone parts as follows:

1. Dial Matrix Assembly consists of push button keypad contacts and light emitting diode (LED) indicator lights. The intended function is to interface with various other electronic circuitry for information input via keyboard entry and as a means of providing the user a visual confirmation and status indication. The dial matrix assembly appears to be a subassembly used in a telephone sets. The applicable HTS subheading for the dial matrix assembly will be 8517.90.3000, which provides for "[p]arts of telephone sets." The rate of duty will be 8.5 percent ad valorem.

2. Network assembly consists of a transformer, resistors and varistors, each of which are mounted on a printed circuit board. The transformer provides hybrid coupling from a 600 ohmage (OHMS) load to two separate loads of differing impedances. It also provides hybrid separation of audio frequency alternating current (AC) signals as well as direct current (DC) coupling. The resistors provide circuit protection and matching. The varistors provide varying impedance, depending upon DC biasing currents. The intended function is to interface with other electronic circuitry for audio signal transfer and impedance balancing. The network assembly also appears to be a subassembly of a telephone set. The applicable HTS subheading for the network assembly will be 8517.90.3000, which provides for "[p]arts of telephone sets." The rate of duty will be 8.5 percent ad valorem.

3. The hookswitch consists of metallic electrical switching contacts actuated by a mechanical lever or plunger. The device operates with voltage up to 56 Vdc. Contact arrangement also provides timing functions; i.e., make before break and/or before make. The intended function is to provide electrical continuity or interruption to other electronic circuitry. Both AC audio frequency and DC signals may function through the contacts of the switch. The applicable HTS subheading for the hookswitch will be 8536.50.0060, which provides for "[e]lectrical apparatus for switching electrical circuits." The rate of duty will be 5.3 percent ad valorem.

4. Key assembly consists of an array of electro-mechanical switches. The switches mechanically interlock such that the depression of one button to a latching position causes any other depressed and latched buttons to be released. The intended function is to provide a means for the user to access alternate circuitries through the use of the various switches. The applicable HTS subheading for the key assembly will be 8536.50.0030, which provides for [e]lectrical apparatus for switching electrical circuits." The rate of duty will be 5.3 percent ad valorem.

5. Cable assembly consists of multiple electrical conductors, individually insulated and enclosed in an insulated jacket. The intended function is to interconnect electrical circuitry between a multi- line telephone and a central control unit which interfaces to PABX or to central office telephone lines. Voltages used are 18 VAC, 10 VAC, and 24 VAC. The applicable HTS subheading for the cable assembly will be 8544.41.0000, which provides for "[i]nsulated cable, whether or not filled with connectors: [o]ther electrical conductors for a voltage not exceeding 80V: fitted with connectors." The rate of duty will be 5.3 percent ad valorem.

Articles classified under subheading 8517.90.3000, HTS, which are products of Mexico, are entitled to duty free treatment under the Generalized System of preferences (GSP) upon compliance with all applicable regulations.

This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177).

A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction.

Sincerely,

Jean F. Maguire
Area Director

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