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NY F83892





March 28, 2000

CLA-2-85:RR:NC:1:112 F83892

CATEGORY: CLASSIFICATION

TARIFF NO.: 8517.50.5000

Mr. Anthony M. Cooper
Tower Group International
128 Dearborn Street
Buffalo, NY 14207-3198

RE: The tariff classification of a CMS transceiver. The country of origin is not stated.

Dear Mr. Cooper:

In your letter dated February 28, 2000, on behalf of Elcombe Systems Limited, you requested a tariff classification ruling.

As indicated by the submitted descriptive literature, the CMS transceiver is a unit that contains an analog telephone line interface circuit, computer interface circuits, a speaker, and a microphone. This unit, which is a component of an Emergency Response System, receives an emergency signal from a receiver base station and retransmits it to various display devices.

The applicable subheading for the CMS transceiver will be 8517.50.5000, Harmonized Tariff Schedule of the United States (HTS), which provides for other apparatus, for carrier-current line systems or for digital line systems: Other: Telephonic. The general rate of duty will be Free.

You have also inquired as to whether a certain modification process is determinative of country of origin for the CMS transceiver. We are unable to determine exactly what this process consists of and, consequently, are unable to provide a reply in this matter. Should you wish to pursue this issue, specific information as to the country of origin of all the components, and a detailed explanation of what conversion processes are performed, must be provided.

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 David Curran at 212-637-7049.

Sincerely,

Robert B. Swierupski
Director,

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