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NY L87508




October 6, 2005

CLA-2-84:RR:NC:1:110 L87508

CATEGORY: CLASSIFICATION

TARIFF NO.: 8471.80.1000; 8471.80.9000; 8473.30.5000; 8507.80.8000

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

RE: The tariff classification of RAID500-RK Array storage subsystem components from Japan

Dear Ms. Churchill:

In your letter dated September 2, 2005 you requested a tariff classification ruling.

Your request concerns five components for the RAID500-RK (Redundant Array of Independent Disks) subsystem. The subsystem uses an enhanced array of inexpensive disks design, which allows for continuous storage, backup and maintenance of the subsystem without having to take the system down. It consists of a disk control frame in the primary rack with up to120 HDDs and a disk array frame (secondary rack) with up to an additional 120 Hard Disk Drive (HDDs). The subsystem can scale from 4 HDDs to 240 HDDs. This model is connectable to both mainframe systems and open systems.

The five components are:
DKC 515I-5R – Control Frame
DKC F515I-B2R – Disk Chassis
DKC F515I-FRMR – 19-inch Rack
DKC F515I-MIX2R – Mix Adapter (Fibre 16-port, Disk Adapter 8-port) DKC F515I-LGABR – Additional Battery

The DKC 515I-5R Control Frame controls up to four disk Chassis (DKC F515I-B2R). It comes in modular form and must be installed in a subsystem Rack (DKC F515I-FRMR). As imported it includes the control electronics and SVP.

The DKC F515I-B2R Disk Chassis consists of four assemblies, each of which can accommodate 15 HDDs for a total of 60. It also comes in modular form and must be installed in a rack. It is imported without any HDDs installed.

The DKC F515I-FRMR Rack is 19” wide. It is imported with four power distribution units (PDUs). In your request you have suggested classification under subheading 8504.40.6018 based on the PDUs. However, the rack/PDU is a component of the storage subsystem, and this combination is not a good of heading 8504. Therefore, Section XVI, Note 2 (b) applies.

The DKC F515I-MIX2R Mix Adapter (Fibre 16-port, Disk Adapter 8-port) is an internal adapter unit that connects the control unit to the drives. It is comprised of two PCAs. It provides both Channel adapter functionality and Disk Adapter functionality. In your request you have suggested classification as a control or adapter unite under subheading 8471.80.1000. However, E.N. 84.71(I)(D) says that “Control and adapter unitseffect interconnection of the central processing unit to other digital data processing machines, or to groups of input or output units.” This subheading is not applicable, since this is an internal adapter and does not interface to the central processing unit.

The DKC F515I-LGABR Additional Battery is a nickel metal hydride battery. It supplies power when AC input power is shut off owing to a power failure.

The applicable subheading for the DKC 515I-5R – Control Frame 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 rate of duty will be Free.

The applicable subheading for the DKC F515I-B2R – Disk Chassis and the DKC F515I-FRMR – 19-inch Rack will be 8473.30.5000, Harmonized Tariff Schedule of the United States (HTS), which provides for “Partssuitable 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 rate of duty will be Free.

The applicable subheading for the DKC F515I-MIX2R – Mix Adapter (Fibre 16-port, Disk Adapter 8-port) will be 8471.80.9000, Harmonized Tariff Schedule of the United States (HTS), which provides for “Automatic data processing machines and units thereofOther units of automatic data processing machines: Other: Other.” The rate of duty will be Free.

The applicable subheading for the DKC F515I-LGABR – Additional Battery will be 8507.80.8000, Harmonized Tariff Schedule of the United States (HTS), which provides for “Electric storage batteriesOther storage batteries: Other.” The rate of duty will be 3.4%.

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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