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NY A89255




November 8, 1996

CLA-2-84:RR:NC:1:110 A89255

CATEGORY: CLASSIFICATION

TARIFF NO.:8473.30.1000

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

RE: The tariff classification of an automatic data processing channel link from Japan.

Dear Mr Rhode:

In your letter dated October 31, 1996, you requested a tariff classification ruling.

The merchandise under consideration involves a Model No. PCA-CHE-OCLINK automatic data processing (ADP) channel link for its Millennium Mainframe computer. When imported, it consists of a printed circuit assembly with eight serial channel elements mounted on it. The system can have a maximum of 256 serial channels (8 PC Board X 32). A serial channel transfers data serially between the channel and an input-output(I-O) device via an optical fiber cable. The maximum transfer rate of a serial channel is 17 megabytes per second. The maximum length of the transfer cable between the serial channel and an I-O device is 3 kilometers. The serial channel can operate in the CNC, CTC, or CVC mode. The control storage (CS) of the serial channel has a capacity of 16 kilowords.

The PCA-CHE-OCLINK contains microcode which controls data transfer between the central processing unit and I/O unit, using SRAM to operate the microcode. This microcode and SRAM have no other function.

The PCA-CHE-OCLINK is for use solely in an automatic data processing system. It connects to the central processing unit (TCMP/SYS Board) through the IOPA and is able to accept or deliver data in a code or signal form which can be used by the system. This PCA-CHE-OCLINK connects mainly to disk drives, tape units, printers, etc., and cannot be connected to LAN, WAN and MAN. As per the inquirer, it cannot transfer voice or fax information.

The PCA-CHE-OCLINK as imported is not a functional or complete digital processing unit noting Legal Note 5(A) to Chapter 84, and upon importation, lacks the "essential character" of a complete or finished ADP machine under the criteria of GRI-2(a).

The applicable subheading for the Model No. PCA-CHE-OCLINK automatic data processing channel link will be 8473.30.1000, Harmonized Tariff Schedule of the United States (HTS), which provides for parts and accessories of the machines of heading 8471, printed circuit assemblies, not incorporating a cathode ray tube. 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

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