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NY R01472




March 8, 2005

CLA-2-85:RR:NC:N1:109 R01472

CATEGORY: CLASSIFICATION

TARIFF NO.: 8517.90.3400

Mr. Michael E. Roll
Pisani & Roll
1875 Century Park East
Suite 600
Los Angeles, CA 90067

RE: The tariff classification of an “Alcatel Part Equipped Logic Shelf (“PELS”)” from an unspecified country

Dear Mr. Roll:

In your letter dated February 11, 2005 you requested a tariff classification ruling on behalf of your client Alcatel Submarine Networks (“ASN”).

This ruling concerns the classification of an “Alcatel Part Equipped Logic Shelf (“PELS”).”

The descriptive literature submitted states that the “Alcatel Part Equipped Logic Shelf (“PELS”)” is a replaceable unit in Alcatel Submarine Networks (“ASN”) Power Feed Equipment (PFE). The PELS houses all logic units of the PFE, which provide control, interface, alarm and monitoring functions. It consists of a number of printed circuit board assemblies (“PCBAs”) assembled into a shelf. In a part equipped format it means that some of the PCBAs are not fitted into the shelf, but are nevertheless, always included in the same shipment. The unit is 470mm by 260mm by 280mm.

The ASN PFE is a hybrid of optical, electronic, and mechanical systems that form part of a submarine telecommunication system for use in transmission of aggregate data (speech & data). The PFE is of an ASN generic design and includes features that allow the configuration of the PFE to suit a given system.

The PFE design incorporates a number of ASN modular units, i.e., parts that support the telecommunications function of the overall PFE. These units are of the ASN PFE and cannot be used independently of it or in other equipment, although they can be interchanged within the PFE cabinet as a spare or replacement for an existing unit. These parts allow the PFE to perform a telecommunication function by providing power to the system. The “Alcatel Part Equipped Logic Shelf (“PELS”)” is part of the Alcatel’s telecommunications PFE.

The applicable subheading for the “Alcatel Part Equipped Logic Shelf (“PELS”)” will be 8517.90.3400, Harmonized Tariff Schedule of the United States (HTS), which provides for “Electrical apparatus for line telephony or line telegraphy, and parts thereof: Parts: Other parts, incorporating printed circuit assemblies: Other.” 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 Hackett at 646-733-3015.

Sincerely,

Robert B. Swierupski
Director,

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