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February 3, 1999

CLA-2-84:RR:NC:1:110 D87315

CATEGORY: CLASSIFICATION

TARIFF NO.: 8471.80.1000

Mr. Joseph A. Nadeau
OpenRoute Networks
9 Technology Drive
Westboro, MA 01581

RE: The tariff classification of Token Ring Network Interface Cards from Singapore

Dear Mr. Nadeau:

In your letter dated January 21, 1999, you requested a tariff classification ruling.

The merchandise under consideration involves four models of Network Interface Cards (Token Ring protocol) that allow personal computers to be networked together and communicate with each other. These products are composed principally of commercial integrated circuits, proprietary ASICS, capacitors, resistors, diodes, crystals, transformers, switches, connectors, and brackets assembled on a printed circuit board according to specific bills of material.

The four models include the following articles: 1. P1392plus (Token Ring Network Card (NIC) for ISA PC slots 2. P1394plus (Token Ring NIC for ISA slots. Has plug/play capability. 3. P1690plus (Token Ring NIC for PCI PC slots 4. P1690plus- AB Dual Token Ring NIC for PCI PC slots. This card is in every way similar to the p1690plus in item 3 except that a few more chips are populated on to the PCB and a different bracket is installed to allow for dual connections.

These NIC devices are designed for incorporation within digital processing machines, such as desk-top and lap-top computers, and appear to be principally used for converting, processing, and formatting data so that several ADP machines or systems are able to communicate and function as a local area network (LAN).

All four of these token ring network interface cards would meet the definition of a “unit” of an ADP system, noting Legal Note 5 (B) to Chapter 84 of the HTS. Since they appear to be principally used for the interconnection of ADP processors to other ADP units within the framework of a LAN system, they would fall under the definition of a control or adaptor unit. Note also HQ ruling letters 952659, 961364, and NY ruling letters A82184 and C86404.

The applicable subheading for the four models of token ring network interface cards will be 8471.80.1000, Harmonized Tariff Schedule of the United States (HTS), which provides for control or adaptor units. 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 212-637-7019.

Sincerely,

Robert B. Swierupski
Director,

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