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NY H81004

June 6, 2001

CLA-2-85:RR:NC:MM:109 H81004


TARIFF NO.: 8517.30.5000

Mr. Soren Beck
Zone Systems Communications Inc.
2623 Arlington Drive
Suite #302
Alexandria, VA 22306

RE: The tariff classification of Change-Over-Unit from Denmark

Dear Mr. Beck:

In your letter dated April 29, 2001, you requested a tariff classification ruling.

The merchandise is described in your letter as a ZS-256 Change-Over-Unit. The Change-Over-Unit is a switching apparatus that can switch between telecommunication equipment connected to the box in the event of a failure of the attached telecommunication equipment. It does not include any transmitter or receiver, but only switches and a system-controller to control the switches. The merchandise can be used in telecommunication for all carrier-current line systems from 0-270 Mbit/sec. The box is used by telecommunication operators to back-up their equipment in the event of equipment failure (the Change-Over-Unit will switch from one piece of telecom equipment to another in the event of failure or malfunction). The unit operates by using switches to direct the input of signals to an output. If a signal fails from a piece of external telecom equipment the signal from similar-stand-by equipment will take over and redirect the signal to the output. The Change-Over-Unit is wired and does not include any transmitter or receiver. The Change-Over-Unit is a part of a system and acts as a switchbox between a number of identical telecommunication apparatus in case of an equipment failure.

The Change-Over-Unit is for carrier-current line systems and does NOT change or modify the signal in any way, but simply lets the signal pass through and in the event of external equipment failure (loss of signal) it will switch to a spare/stand by telecommunication equipment. It is NOT a service device, but will transport telecommunication data (voice, video and data) without any modification to the signals. The unit has NO specific relation to the WAN, but can switch and redirect data from WAN equipment in similar way like other data and signals as a back-up.

The applicable subheading for the Change-Over-Unit will be 8517.30.5000, Harmonized Tariff Schedule of the United States (HTS), which provides for “Electrical apparatus for line telephony or line telegraphy, including line telephone sets with cordless handsets and telecommunication apparatus for carrier-current line systems or for digital line systemsTelephonic or telegraphic switching 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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