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NY 811909

June 27, 1995

CLA-2-84:S:N:N1:110 811909


TARIFF NO.: 8471.99.1500

Mr. Anthony R. Pranses
Rudolph Miles & Sons, Inc.
4950 Gateway East
P.O. Box 11057
El Paso, Texas 79983

RE: The tariff classification of computer network interfacing devices from Mexico.

Dear Mr. Pranses:

In your letter dated June 14, 1995, on behalf of Xircom Inc., you requested a tariff classification ruling.

The merchandise under consideration involves ADP interface devices which are known as the CE-10B2-MAU, the CEM-10BT-DAA, and the PPX-03 models. These devices are terminated to conductive cable rather than being housed in a single unit.

The CE-10B2-MAU and the CEM-10BT-DAA devices provide both physical and data-link interfaces between a data network such as an Ethernet Local Area Network (LAN) or the Public Switched Telephone Network (PSTN) and a Xircom Network Interface Card (NIC) installed inside a computer. The physical and data-link interface functions include analog to digital and digital to analog data conversion, and related activities. Although the CEM-10BT-DAA does link a modem with a PSTN, it also provides other functions including signaling network status to the host computer through the attached Xircom NIC. Data transmission between the CEM-10BT-DAA and the LAN occurs through the Xircom Network Interface Card.

The model PPX-03 device performs electronic signal switching under software control. It is directly attached to a computer's parallel port interface, and facilitates the sharing of multiple peripherals such as LAN interface devices, printers, and security keys. This device includes internal digital logic that examines the parallel data stream for indication to switch channels from one port to another port.

Noting Legal Note 5(B) to Chapter 84 of the HTS, these devices appear to be principally used to connect the central processing unit to other units or ADP machines, thereby serving "control" and "adaption" functions. Please note also Headquarter's Ruling Letters 953205, 953921, and 957325 which involved similar merchandise.

The applicable subheading for the models CE-10B2-MAU, the CEM-10BT-DAA, and the model PPX-03 will be 8471.99.1500, Harmonized Tariff Schedule of the United States (HTS), which provides for control or adapter units for automatic data processing machines. The rate of duty will be free.

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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