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NY K86496




June 9, 2004
CLA-2-84:RR:NC:1:110 K86496

CATEGORY: CLASSIFICATION

TARIFF NO.: 8471.70.4065; 8471.80.1000; 8473.30.5000

Ms. Jennifer Churchill
Hitachi Computer Products (America), Inc. 1800 E. Imhoff Road
Norman, OK 73071-1202

RE: The tariff classification of subsystems for Hitachi’s array disk storage system from Japan and the Philippines.

Dear Ms. Churchill:

In your letter dated May 25, 2004 you requested a tariff classification ruling.

The merchandise under consideration involves five subsystems for Hitachi’s RAID500, the next generation of Hitachi's Array Storage Subsystems. The earlier version (RAID450) array storage subsystems were the subject of NY H89358. The RAID500 consists of up to four disk storage units "DKU" and a disk control unit "DKC". The five subsystems for this ruling request are model number’s DKC510I-5 (Disk Controller Frame), DKU505I-18 (Disk Array Frame), DKC-F510I-800 (High Performance Disk Adapter) and DKC-F510I-32HS (Fibre 32-Port High Performance Adapter) all imported from Japan, and model DKU-F505I-146JS (Hard Disk Drive Canister) imported from the Philippines.

The DKC510I-5 is the Disk Controller Frame without doors. This is one cabinet in the RAID500 system and performs as an interface between the subsystem’s DKU storage units and the central processing unit (CPU). The Disk Controller Frame is the disk subsystem’s basic unit and consists of channel adapters, disk adapters, cache memory, shared memories, control panel, power supplies, battery boxes and a HDU Box in which disk drives may be installed. This cabinet measures approximately 30.8 inches wide by 36.4 inches deep and is 73.2 inches high. The control unit is equipped with an SVP (Special PC), which is used to service the subsystem, monitor its running condition, and analyze faults.

The DKU505I-18 Disk Array Frame is a single cabinet that connects to the Disk Controller Frame. The Disk Array Frame consists of four HDU Boxes capable of holding up to 64 disk drivers each. This unit is equipped with cooling fans, power supplies and Battery Boxes. The DKU505I-18 cabinet measures approximately 25.6 inches wide by 36.4 inches deep and is 73.2 inches high. It will be imported without any hard disk drive (HDD) canisters installed. Noting HQ954361, it does not meet Chapter 84, Note 5(B) with regard to units. In your letter you suggest classification under 8471.70.5065. This item however is not imported with HDDs installed and therefore is precluded from heading 8471.

The DKU-F505I-146JS Hard Disk Drive Canister’s are designed to be installed into the HDU Boxes. Each canister contains a 3 inch 146GB Hard Disk Drive (HDD), power connector, disk drive interface connector and DC-DC converter. At the time of import the canisters contain the read/write printed circuit assemblies.

The DKC-F510I-800 High Performance Disk Adapter is used for controlling data transfer between the cache and disk drives. This unit consists of two disk adapter PCBs (Printed Circuit Boards) that control eight 2-Gbps fibre ports using the eight microprocessors. In your letter you suggest that the disk adapter be classified in subheading 8471.80.1000 as a control or adapter unit. However, Explanatory Note 84.71 states that a control and adapter unit “effect interconnection of the central processing unit to other digital data processing machines, or to groups of input or output units.” The disk adapter is an internal interface of the RAID. It does not interconnect the RAID to the central processing unit (CPU) of an automatic data processing (ADP) machine or system. It is, therefore, not considered a control or adapter unit.

The DKC-F510I-32HS Fiber 32-Port High Performance Adapter is a channel adapter consisting of 32 1-2Gbps fibre channel ports conforming to short wavelength (multi-mode). This item is composed of two channel adapter PCBs each mounted with 16 fibre channel ports and the transceiver conforming to the short wavelength as the standard. The channel adapter (CHA) controls data transfer between the upper host and cache memory.

The applicable subheading for DKU-F505I-146JS Hard Disk Drive Canister’s imported separately from the Philippines will be 8471.70.4065, Harmonized Tariff Schedule of the United States (HTS), which provides for “Automatic data processing machines and units thereofStorage units: Magnetic disk drive units: Other: Not assembled in cabinets, and without attached external power supply: Hard magnetic disk drive units.” The general rate of duty will be free.

The applicable subheading for the DKC510I-5 Disk Controller Frame and the DKC-F510I-32HS Fiber 32-Port High Performance Adapter will be 8471.80.1000, Harmonized Tariff Schedule of the United States (HTS), which provides for “Automatic data processing machines and units thereofOther units of automatic data processing machines: Control or adapter units.” The general rate of duty will be free.

The applicable subheading for the DKC-F510I-800 High Performance Disk Adapter and the DKU505I-18 Disk Array Frame imported without the Hard Disk Drive Canisters will be 8473.30.5000, Harmonized Tariff Schedule of the United States (HTS), which provides for “Parts and accessoriessuitable for use solely or principally with machines of headings 8469 to 8472: Parts and accessories of the machines of heading 8471: Not incorporating a cathode ray tube: Other.” The general 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 Eileen S. Kaplan at 646-733-3016.

Sincerely,

Robert B. Swierupski
Director,

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