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NY N025237




April 4, 2008

CLA-2-85:OT:RR:E:NC:N1:109

CATEGORY: CLASSIFICATION

TARIFF NO.: 7616.99.5090 8517.62.0050 8517.70.0000

Ms. Melissa Hoffman
Compliance Specialist III
Ericsson, Inc.
6300 Legacy Drive
Plano, TX 75024

RE: The tariff classification of a Module Unit (MMU), a Switch Multiplexer Unit (SMU), a Service Access Unit (SAU), an Access Module Magazine (AMM), and an antenna mounting kit from Sweden

Dear Ms. Hoffmann:

In your letter dated March 25, 2008 you requested a tariff classification ruling.

The merchandise subject to this ruling is a Module Unit (MMU), a Switch Multiplexer Unit (SMU), a Service Access Unit (SAU), an Access Module Magazine (AMM), and an antenna mounting kit. These items are used in the telecommunications environment for the transmission and reception of voice, speech, and data. These devices are components within a MiniLink E system, which is a point to point microwave transmission communications system. The MiniLink E system is used in areas where the use of radio transmission is cost prohibitive or unfavorably impacted by the terrain.

The MiniLink E system is comprised of indoor and outdoor components. The indoor components consist of the MMU, the SMU, and the SAU, all housed in one common AMM. The outdoor components consist of an antenna, an antenna mounting kit, and a Radio Unit (RAU). This ruling, however, pertains only to the MMU, SMU, SAU, AMM, and the antenna mounting kit.

The Module Unit (MMU) provides traffic interfaces, signal processing, and is the indoor interface with the Radio Unit (RAU) within the MiniLink E system. The following functional blocks are included in the MMU:

Traffic Interface
Radio Frame Multiplexer/Demultiplexer for traffic and service channels insertion/extraction and Forward Error Correction (FEC) encoding/decoding Modulator/Demodulator for transmitting signal modulation and receiving signal demodulation Cable Interface with the RAU
Control and Supervision processor
DC/DC converter

The Switch Multiplexer Unit (SMU) provides multiplexing/demultiplexing, switch and control functions for 1+1 protected systems, and traffic interfacing with the MMUs within the MiniLink E system. The following functional blocks are included in the SMU:

Traffic Interface
1+1 switch logic and control circuitry for 1+1 protection switching and input/output selection for the multiplexers Control and supervision processor
DC/DC converter
One or several multiplexers/demultiplexers

The Service Access Unit (SAU) comes in three different configurations and provides parallel input/output ports, external alarm and service channel interfaces. It also provides control and supervision functionality to collect alarms, and control settings and tests within the MiniLink E system.

The following functional blocks are included in the basic SAU:

Two External Alarm Channel (EAC) ports
Eight User Input ports
Four User Input/Output ports (individually selectable) Control and supervision processor
DC/DC converter

The SAU is also available in the EXP 1 version. This version includes the following functions in addition to the basic functional blocks listed above:

Two digital service channels per radio terminal Two Remote Alarm Channel (RAC) ports

There is also a version of the SAU called the IP (SAU). It provides routing of IP Data Communication Network data from MiniLink Traffic Node terminals over MiniLink E terminals, utilizing the 64 Kbit/s digital service channels. The unit can be placed, as the other types of SAU, in an AMM within the MiniLink E system.

The Access Module Magazine (AMM), which is imported without the plug-in units (the MMU, SMU, and SAU) is not capable of receiving, converting, and transmitting or regenerating voice, images, or other data. It is, however, designed and dedicated to house the plug-in units within the telecommunications environment of the MiniLink E system. As such, it is a part of telecommunications apparatus within the MiniLink E system.

The antenna mounting kit consists of two rigid, extruded aluminum brackets connected with two stainless steel screws along the azimuth axis. The brackets are anodized and have threaded and unthreaded holes to provide adjustment of the antenna in azimuth and elevation. The support can be clamped to poles with a diameter of 2 inches – 4 ¾ inches (50 – 120 mm) or on L-profiles, 1 ½ inches x 1 ½ inches x ¼ inches – 3 inches x 3 inches x ½ inch (40 x 40 x 5 – 80 x 80 8 mm). The antenna mounting kit is utilized within the MiniLink E system.

You suggested that the antenna mounting kit should be classified under subheading 8302.50.0000 of the Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Hat racks, hat pegs, brackets and similar fixtures, and parts thereof.” The antenna mounting kit consists of two rigid, extruded aluminum brackets connected with two stainless steel screws along the azimuth axis. The documentation that you submitted indicates that these brackets can be clamped to poles with a diameter of 2 inches to 4 ¾ inches or on L-profiles, 1 ½ inches x 1 ½ inches x ¼ inches – 3 inches x 3 inches x ½ inch. The brackets included in the antenna mounting kit are not like the brackets classified in subheading 8302.50, HTSUS. Rather, they are mountings, which are classified in heading 8302 only if they are suitable for “furniture, doors, staircases, windows, blinds, coachwork, saddlery, trunks, chests, caskets or the like.” Since these brackets are used to mount the antenna to poles, and poles are not like the exemplars listed in heading 8302, classification within subheading 8302.50.0000 is inapplicable.

The applicable subheading for the antenna mounting kit will be 7616.99.5090, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Other articles of aluminum: Other.” The rate of duty will be 2.5 percent ad valorem.

The applicable subheading for the Module Unit (MMU), Switch Multiplexer Unit (SMU), and the three configurations of the Service Access Unit (SAU) will be 8517.62.0050, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Machines for the reception, conversion and transmission or regeneration of voice, images or other data, including switching and routing apparatus: Other.” The rate of duty will be free.

The applicable subheading for the Access Module Magazine (AMM) will be 8517.70.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "Other apparatus for transmission or reception of voice, images or other data, including apparatus for communication in a wired or wireless network (such as local or wide area network), other than transmission or reception apparatus of heading 8443, 8525, 8527, or 8528; parts thereof: Parts." The rate of duty will be free.

Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.

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 646-733-3015.

Sincerely,

Robert B. Swierupski
Director,

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