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NY 805143

January 2, 1997



TARIFF NO.: 8471.99.1500

MS. Eileen M. Madden
Amdahl Corporation
1250 East Arques Avenue
P.O. Box 3470
Sunnyvale, CA 94088-3470

RE: The tariff classification of Channel and Processor Frames from Japan.

Dear Ms. Madden:

In your letter dated December 14, 1994, you requested a tariff classification ruling.

This letter will be given confidential treatment based on the facts you supplied to support your claim for exemption from disclosure.

The merchandise under consideration involves a next generation mainframe computer that consists of two frames: the processor frame and the channel frame.

The processor frame, when completely assembled, contains:
a. One tightly coupled multi processor (TCMP) b. memory boards referred to as Super Integrated Memory Modules (SIMMs) c. Fan units which provide cooling for the operating TCPMs. d. A card cage, housing printed circuit assemblies, and various rectifiers and power converters.

The channel frame, when completely assembled, contains:
a. Service processor which consists of various processing and memory PCAs, hard and floppy disk drives, and a status panel allowing for system interface with the TCPMs. b. Channel Unit card cage and channel PCAs for interconnection to external devices such as direct access storage devices. c. Power input module, and EMI filter and circuit breaker panel.

The processor frame and the channel frame will be imported bolted together, but will lack the additional Frame C, Channel PCAs, Presentation Element Processor (PEP), PCA SIMMs, and the TCPMs. The two electro-mechanical frames act as cabinets with shelves for mounting boards. The TCMP board is the main processing board in the machine and has up to 8 CPUs, memory and memory control components. The SIMMs are memory modules of different memory capabilities. The PCAs are adapter type of boards, and when used with the TCMP, provide the link to physical Input/Output devices and link to the System Control Console. The Presentation Element Processor (PEP), is a US sourced Personal Computer that is modified in order to use as a system configuration, control and test console.

Noting Legal Note 5 (A) to Chapter 84 of the HTS, and GRI 2 (a), in the condition as imported, the two frames that are bolted together, would not appear to meet the definition of a digital processing machine. The frames lack the "essential character" of a digital processing machine since they are without the Channel PCAs, PEP parts, PCA SIMMs, and the TCMPs.

The two frames do however meet the definition of a "unit" of an ADP system as defined in Legal Note 5 (B) to Chapter 84 of the HTS. They are connectable to the central processing unit either directly or through one or more other units, and are specifically designed as part of such a system and be able to accept or deliver data in a form (code or signals) which can be used by the system. The two frames will be imported as a single unit, with bolts connecting the frame members and with all cables and connecting devices attached between the frames. The principal function of this subassembly unit appears to be for the interconnection of the mainframe's TCMP to other input and output units. It thus would fall under the definition of a control or adapter unit under HTS number 8471.99.15.

The applicable subheading for the processor and channel frames will be 8471.99.1500, Harmonized Tariff Schedule of the United States (HTS), which provides for control or adapter units. 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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