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NY G86274

February 12, 2001

CLA-2-85:RR:NC:MM:109 G86274


TARIFF NO.: 8517.90.3800

Mr. Neil R. Trenchard
Manager, Import/Export Operations
Siemens Shared Services, LLC
186 Wood Avenue South
Iselin, NJ 08830

RE: The tariff classification of PUMP Plug-in Modules from Germany

Dear Mr. Trenchard:

In your letter dated January 2, 2001, you requested a tariff classification ruling.

The merchandise is a PUMP Plug-in Module. The PUMP Plug-in Module is a specially designed printed circuit assembly for the use in the TransXpress Infinity telecommunications equipment. TransXpress Infinity is a telecommunications transmission system for the transport of voice or data signals over long distances using optical fiber as the transmission medium. The TransXpress Infinity transmission system is purchased and installed by traditional local telephone companies and long-distance providers to carry everyday telephone, FAX and data service for businesses and the general public. The PUMP Plug-in Modules interface with this system Optical Line Interface (OLI) Module to further increase the amplification ability for network architecture that requires increased power.

You have provided information for two (2) types of PUMP Modules; the PUMP 17 and the PUMP 20. The difference between the two pumps is that the PUMP-17 increases the output from +14 dBm to +17 dBm while the PUMP-20 increases the output from +14 dBm to +17 dBm. Both PUMP Plug-in Modules augment the output power of the OLI Module. The OLI Module contains a pumping laser diode and a piece of Erbium-doped fiber. The PUMP-17 features one 1,480 nm “pumping” (send light through) laser diode, whereas the PUMP-20 contains two such diodes. The PUMP-17 or PUMP-20 card provides additional pumping power via their additional laser diode(s) to amplify the power of the traffic-carrying wavelengths be transmitted by the TransXpress Infinity. In additional to the laser diodes, the PUMP Plug-in Modules contains a printed circuit assembly consisting of a local card controller, power supply and an optical coupler. The PUMP Plug-in Module is physically connected to the OLI Module via a short fiber pigtail so that the PUMP card’s extra “pumping power” is coupled to the OLI’s own Erbium-Doped Fiber Amplifier (EDFA) for increased signal launch power.

Your letter suggests Headings 8517 and 9013 as possible classifications for the PUMP Plug-in Module. You were considering subheading 9013.80, which provides for optical appliance or optical instrument. However, the Pump Plug-in Modules do not contain the Erbium-doped optical fiber, which is an optical element that would qualify this item for classification as an optical appliance or optical instrument under subheading 9013.80. It is the OLI Module that contains the Erbium-doped optical fiber, which facilitates the amplification power of the traffic-carrying wavelengths being transmitted. Therefore, subheading 9013.80 would not apply to the PUMP Plug-in Modules.

Subheading 8517.90 provides for telecommunication apparatus for carrier-current line systems or for digital line systems. The PUMP Plug-in Modules are specially designed printed circuit assembly (containing a local card controller, power supply and optical coupler) for the use in the TransXpress Infinity telecommunications equipment. Therefore, subheading 8517.90, parts of telecommunications apparatus, would apply.

The applicable subheading for the PUMP Plug-in Modules is 8517.90.3800, Harmonized Tariff Schedule of the United States (HTS), which provides for “Printed circuit assemblies: For telephonic apparatus: Other.” The rate of duty will be free.

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 212-637-7048.


Robert B. Swierupski

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