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NY B80449




December 23, 1996

CLA-2-84:RR:NC:1:110 B80449

CATEGORY: CLASSIFICATION

TARIFF NO.: 8471.80.1000

Mr. Steve Rhode
Fujitsu America, Inc.
1741 Junction Avenue
San Jose, California 95112-1010

RE: The tariff classification of an automatic data processing network interface device from Japan.

Dear Mr. Rhode:

In your letter dated November 5, 1996, you requested a tariff classification ruling.

The merchandise under consideration involves a model number PCA-CHE-OEMI network interface device which functions as a channel unit for data transfer between input and output (I/O) units. Four channel elements (CHEs) which control each channel and a channel adapter (CHA) which connects these CHEs with PCA-IOPA-CH are mounted on this PCA-CHE-OEMI. The CHEs and I/O devices are connected by electronic cables exclusively used for this connection.

Each CHE can operate individually under control by micro programs on each CHE. The CHES have the capability of performing the following functions: 1) Read/analyze/prosecute Channel Command Word (CCW); 2) Data Transfer to and from, I/O devices; and 3) Analyze I/O device status. The PCA-CHE-OEMI channel device is a board related product. This device has the approximate size of 237mm by 381mm.

This PCA is not connected with a public telephone line. It is used for transferring data to and from input/output devices. The PCA is mainly used for connection with disk units, magnetic tape units, printers and display units, etc. Noting Legal Note 5(B) to Chapter 84, the PCA would appear to meet the definition of a "unit" of an automatic data processing (ADP) system. It is principally used to interconnect ADP processors with other ADP units.

The applicable subheading for the PCA-CHE-OEMI channel interface unit will be 8471.80.1000, Harmonized Tariff Schedule of the United States (HTS), which provides for other control or adapter units for use with automatic data processing machines. 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 Art Brodbeck at 212-466-5490.

Sincerely,

Roger J. Silvestri
Director

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