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NY 843419

Aug 8, 1989

CLA-2-85:S:N:N1:109 843419


TARIFF NO.: 8517.81.0020

Ms. Joan M. McLeod
Northern Telecom Inc.
77 Oriskany Drive
Tonawanda, New York 14150

RE: The tariff classification of a traffic operator position system (TOPS) and auxiliary operator services system (AOSS) from Canada.

Dear Ms. McLeod:

In your letter dated July 13,1989 you requested a tariff classification ruling.

The submitted literature describes the AOSS and TOPS equipment as follows:

1. The auxiliary operator services system (AOSS) is a new system integrating operator services with a toll switching system. The AOSS system hardware is comprised of operator and supervisory positions, printers, and DMS service circuits. The operator and supervisory positions are equipped with voice and data circuits both terminating on the DMS-200 peripheral subsystem. Upon system initialization are connected via the switching network to digital signal processor circuits. The signal processors perform the function of a modem eliminating the need for an external modem. When an incoming call is received, the calling party is connected to the positions voice circuit. If the operator requires assistance from a supervisor in processing the call a three-way conference circuit is switched into the connection permitting a simultaneous conversation between the operator, the supervisor, and the calling party. The AOSS is designed for auxiliary operator services, such as directory assistance and intercept that do not require connection to a called party.

2. The traffic operator position system is the toll member of the DMS-100 family of digital multiplex systems. Calls received by the network are routed to the TOPS or AOSS positions as a result of a subscriber dialing the access code for the purpose of obtaining a special service, ie: credit card calls. When a signal is received the operator keys the information to the Central Control Complex where the input information for billing purposes and validity of credit card numbers. When an error is detected, the Central Control Complex advises the operator of the nature of the error through the display unit and the call is completed only when the correct details are keyed in. TOPS systems are used for all types of operator assistance calls which include person to person calling, coin calls, or information on time and charges as requested by the caller. AOSS systems are dedicated to directory assistance calls. The TOPS and AOSS systems appear to be dedicated to the transmission between two points electrical impulses representing speech or other sounds, text and/or images, and other data using a line connection connecting the transmitting station to the receiving station.

The applicable subheading for the TOPS and AOSS systems will be 8517.81.0020, Harmonized Tariff Schedule of the United States (HTS), which provides for "[o]ther telephonic apparatus." The duty rate will be 8.5 percent ad valorem.

Goods classifiable under subheading 8517.81.0080, HTS, which have originated in the territory of Canada, will be entitled to a 6.8 percent ad valorem rate of duty under the United States - Canada Free Trade Agreement (FTA) upon compliance with all applicable regulations.

Your inquiry does not provide enough information for us to give a classification ruling on components when shipped separately. Your request for a classification ruling should include information explaining whether the CRT monitor, keyboard, controller, display monitor, and training apparatus can be used with data processing machines such as personal computers. If so please explain fully.

This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177).

A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction.


Jean F. Maguire
Area Director

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