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NY H81060




June 14, 2001

CLA-2-85:RR:NC:MM:109 H81060

CATEGORY: CLASSIFICATION

TARIFF NO.: 8517.90.4400

Mr. Dan Magee
Professional Services Group
Circle International, Inc.
1619 F Diamond Springs Road
Virginia Beach, VA 23455

RE: The tariff classification of Alarm Card-B350, IVSN Fan Control Card, Power Filter Card NB350, External Cache, and M2 ECB Module from Scotland

Dear Mr. Magee:

In your letter dated May 11, 2001, you requested a tariff classification ruling on behalf of CTS Interconnect systems. A sample of each of the items was received and is being returned to you.

The Alarm Card-B350, Part No. 87-2215-01 is a printed circuit assembly for a digital subscriber line (DSL) telecommunications control switch. It is used in the Alcatel 7350 ASAM carrier class (central office) service access node that enables broadband multiservice and multi-access technologies. It supports advanced Internet protocol (IP) and current voice and data services (voice, video, and data).

The applicable subheading for the Alarm Card-B350, Part No. 87-2215-01 will be 8517.90.4400, Harmonized Tariff Schedule of the United States (HTS), which provides for “Printed circuit assemblies: For telegraphic apparatus”. 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 Linda M. Hackett at 212-637-7048.

The classification of the IVSN Fan Control Card (Part No. 87-2218-01), Power Filter Card NB350 (Part No. 87-2219-01), External Cache (Part No. 54-23424-01), and M2 ECB Module (Part No. 54-25535-01) cannot be provided, at this time, because it is not certain as to whether these items are printed circuit assemblies or if they complete power supplies or some other device. Please provide the following information, which will enable us to identify the merchandise and determine a classification. Kindly be specific and describe each item in layman’s terms:

IVSN Fan Control Card (Part No. 87-2218-01): The description provided states that this is a cooling unit card, monitors environmental input to control fans in the telecommunications control switch. Your cover letter states that all the items within the ruling request were printed circuit assemblies. Is this item a printed circuit assembly? Or, is it a speed drive controller for an electric motor? If this is a printed circuit assembly, what does the assembly consist of? List all electronic component, connectors, switches, and other items within. Please describe the function of each of the components. Provide a schematic labeling all the electronic components, connectors, switches, etc. If this is a printed circuit assembly, in what device will it be used? What role will the printed circuit assembly play within the device it gets assembled into? If this is a speed drive controller, where will it be used, specifically? In what industry? What is the role or function of the speed drive controller? How does the speed drive controller actually function to its intended purpose?

Power Filter Card NB350 (Part No. 87-2219-01): Is this a printed circuit assembly?
If this is a printed circuit assembly, what does the assembly consist of? List all electronic component, connectors, switches, and other items within. Please describe the function of each of the components. Provide a schematic labeling all the electronic components, connectors, switches, etc. If this is a printed circuit assembly, what role will it play within the device it gets assembled into? If this is a printed circuit assembly, is it a power board? If so, what is it powering?
If this is not a printed circuit assembly, what is the Power Filter Card NB350 (Part No. 87-2219-01), what does it do, how does it function, in what industry is it used and where is it used specifically?

External Cache (Part No. 54-23424-01) and M2 ECB Module (Part No. 54-25535-01): Your description states that these each contain an external cache battery, PCA, and battery charge controller. a) Are these both printed circuit assemblies or are they two separate and distinct devices? b) If these are printed circuit assemblies, what do each of the assemblies consist of? List all electronic components, connectors, switches, and other items within. c) Please describe the function of each of the components. d) Provide a schematic labeling all the electronic components, connectors, switches, etc. e) If these are not a printed circuit assemblies, what is the External Cache (Part No. 54- 23424-01) and what is the M2 ECB Module (Part No. 54-25535-01), what do they each do, how do they function, in what industries are they used and where are they each used specifically? f) On the graph within your ruling request, there were various columns providing information about each product. On the line for the M2 ECB Module it indicated Part No. 54-25535-01 and 74HCT04 HEX Inverter SOIC. Is the M2 ECB Module actually an Inverter? g) Please describe how the External Cache (Part No. 54-23424-01) and M2 ECB Module (Part No. 54-25535-01) are similar or how they differ.

When this information is available, you may wish to consider resubmission of your request. If you decide to resubmit your request, please reference this ruling number NY H81060 and include all of the material that we have returned to you pertaining to this ruling. Mail your request to U.S. Customs, Customs Information Exchange, Room 437, NIS-112, 6 World Trade Center, New York, NY 10048, attn: Binding Rulings Section. If you have any questions regarding these questions, contact National Import Specialist Linda M. Hackett at 212-637-7048.

Sincerely,

Robert B. Swierupski
Director,

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