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NY C86681




April 22, 1998

CLA-2-84:RR:NC:1:110 C86681

CATEGORY: CLASSIFICATION

TARIFF NO.: 8471.80.9000

Mr. James Shaw
Panasonic Logistics Co.
2 Panasonic Way
Secaucus, N.J. 07094

RE: The tariff classification of a Cabin Passenger Management Unit (CPMU) from Japan.

Dear Mr. Shaw:

In your letter dated April 17, 1998, you requested a tariff classification ruling.

The merchandise under consideration involves a cabin passenger management unit that is a component of the Interactive Cabin Passenger Management Service network aboard an aircraft.

The (CPMU) described as model RD-AA8001-XX, provides an ARINC 429 interface to various external systems aboard the aircraft. It interfaces with 12 ARINC 429 ports, and the data received from these interfaces will be passed on to the Cabin management expansion unit or other units such as the Cabin Management Unit and File Server for further processing. It is a free standing unit with a cabinet around it, and has a power input of AC 115V, 400Hz. The CPMU communicates with the other units through a 16 MB IEEE 802.5 token ring network via two 100-ohm shield twisted pairs.

While the CPMU in part does perform interconnection functions between some automatic data processing machines, it also interconnects to non-ADP machines. The CPMU also performs in part signal converting functions. Noting in part Legal Note 5 (B) to Chapter 84 of the HTS, and HQ ruling 955873, we would consider this device to fall under the definition of a "unit" of an ADP system, other.

The applicable subheading for the Cabin Passenger Management Unit will be 8471.80.9000, Harmonized Tariff Schedule of the United States (HTS), which provides for other units of automatic date 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,

Robert B. Swierupski
Director,

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