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NY E89227

November 4, 1999

CLA-2-84:RR:NC:1:110 E89227


TARIFF NO.: 8471.80.1000; 8529.10.9000

Ms. Gail T. Cumins
Sharretts, Paley, Carter & Blauvelt, P.C. 75 Broad Street
New York, N.Y. 10004

RE: The tariff classification of Wireless LAN products from Sweden

Dear Ms. Cumins:

In your letter dated October 28, 1999, on behalf of Ericsson Inc., you requested a tariff classification ruling.

The merchandise under consideration involves various models of wireless LAN products that includes the following: WLAN Access Point A3 (KRD 151 01 & KRD 151 02); WLAN Card C3 (KRD 151 11); WLAN Bridge (KRD 151 21); and WLAN Antenna Unit (KRE 105 49 & KRE 105 50).

The WLAN Access Point A3 (KRD 151 01 & KRD 151 02) is the hub of the wireless system/network. This device is the part that is actually connected to an existing office’s LAN, creating a plug-and play Ethernet system. Connection to the wired LAN is done through the 10BaseT with a RJ-45 connector, enabling transmission of network information from wired LAN to wireless users, either stationary or mobile. Model KRD 151 02 and KRD 151 01 both connect the cells of the wireless LAN with one another and connects the wireless LAN cells to a wired Ethernet LAN via a cable connection to an Ethernet LAN outlet. Both incorporate integrated omni-directional retractable antennas, and are approximately 5.1 inches in length, and 3.4 inches in width. Since these devices serve as the interface or adapter between the host computer and the data collection device, they function primarily as the interconnection device between a computer and the LAN units of the ADP system.

The WLAN Card C3 (KRD 151 11) is a credit card size adapter device that easily fits into one of the mobile computer’s standard PCM-CIA type II card slots. Once installed in a laptop computer and set up with the supplied software, it creates a mobile terminal that can be connected wireless, to the wireless Local Area Network. It incorporates two small, retractable antennas and supports Windows 95/98. It can handle data rates of up to 3 Mbps in a wide coverage area. Since this card is basically performing an interconnection function between ADP units, it appears to function principally as an adapter unit.

The WLAN Bridge B3 (KRD 151 21) is the extension link in a wireless network and the mobile computer users connection to remote locations such as another office building. It is designed for a coverage range of about 600 meters in an open space and is interfaced through a 10BaseT with a RJ45 connector. It is compliant with Ethernet/IEEE 802.3 and incorporates 2 retractable antennas. Like the other LAN products, this Bridge device functions primarily as an interconnection device between ADP units in a LAN environment, and thus would meet the definition of a control/adapter unit. Please note also HQ rulings 952659, 953330 and NY ruling 804249 for similar merchandise.

The WLAN Antennas (OMNI-6 and UNI-8.5) extend the outdoor range of the wireless network from 750 feet to 4000 feet, thereby making it possible to connect different office buildings for a campus-like environment. The OMNI-6 antenna is for use with the WLAN Access A3 and is easily mounted on an outer wall or roof mast. The UNI-8.5 is designed for linking the wireless network and is suited for use with the WLAN Access point and WLAN Bridge B3.

The applicable subheading for the WLAN Access Point devices, WLAN Card C3 and WLAN Bridge will be 8471.80.1000, Harmonized Tariff Schedule of the United States (HTS), which provides for control or adapter units. The rate of duty will be free.

The applicable subheading for the two WLAN Antenna units will be 8529.10.9000, HTS, which provides for other antennas and antenna reflectors of all kinds. The rate of duty will be 3 percent ad valorem.

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 Art Brodbeck at 212-637-7019.


Robert B. Swierupski

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