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NY R01514




March 16, 2005

CLA-2-85:RR:NC:N1:109 R01514

CATEGORY: CLASSIFICATION

TARIFF NO.: 8517.50.9000

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

RE: The tariff classification of an “Alcatel Alarm Unit No. ” from an unspecified country

Dear Mr. Roll:

In your letter dated February 21, 2005 you requested a tariff classification ruling on behalf of your client Alcatel Submarine Networks (“ASN”).

This ruling concerns the classification of an “Alcatel Alarm Unit No .”

The descriptive literature submitted states that the “Alcatel Alarm Unit No. ” is a replaceable unit in Alcatel’s Power Feed Equipment (PFE). The “Alcatel Alarm Unit No. ” monitors several alarm conditions within the PFE, and passes the state of those alarms to the micro unit for appropriate action, as well as logging and displaying the information to the operator. The unit is 20mm by 260mm by 190mm.

The “Alcatel Alarm Unit No. ” is one of several parts for the Alcatel PFE for submarine telecommunications systems. The 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 Alarm Unit No. ” is part of the Alcatel’s telecommunications PFE.

The applicable subheading for the “Alcatel Alarm Unit No. ” will be 8517.50.9000, Harmonized Tariff Schedule of the United States (HTS), which provides for “Other apparatus, for carrier-current line systems or for digital line systems: Other: Telegraphic: 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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