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NY J88769

October 3, 2003

CLA-2-85:RR:NC:MM:109 J88769


TARIFF NO.: 8517.50.5000 8517.90.5200

Ms. Barbara Dawley
Meeks & Sheppard
Attorneys at Law
1735 Post Road
Suite 4
Fairfield CT 06824

RE: The tariff classification of telecommunications apparatus and parts thereof from the Dominican Republic

Dear Ms. Dawley:

In your letter dated September 11, 2003, you requested a tariff classification ruling, on behalf of your client Corning Cable Systems, LLC (“Corning”).

The merchandise is described in your letter as four articles, which are solely used for telecommunications purposes with carrier-current line systems. The carrier-current line systems on which they are used are traditional copper-based telecommunications systems that operate on 48-Volt direct current (DC). Each of the subject articles is installed in the telephone network to complete the connection between the telephone company network and the end user telephones. These four items are 1) - a solid state protected terminating device (PTD), identified as Part Number PTD-3L1H, 2) - a network interface device (NID), identified as Part Number CAC-200, 3) - an adaptor, identified as Part Number 15-184-60, and 4) - a module assembly, identified as Part Number 15-200-68. A sample of each of these four items was submitted to this office for classification purposes

Part Number PTD-3L1H is a patented protection terminating device (PTD) module, which provides protection and terminating in one compact unit. It combines line protection, line test electronics, environmentally sealed insulation displacement telco terminations, a subscriber bridge and an RJ-11 test jack. This device is inserted into a weather-resistant enclosure box designed for indoor or outdoor applications. It is installed at the premises of a telephone subscriber.

Part Number CAC-200 is a network interface device (NID), which houses one or two over voltage protection devices, and one or two modules (designed as Part Number 15-200-68). The protection device and module are mounted in the housing by means of an adaptor (Part Number 15-184-60). The CAC-200 serves as the demarcation point where the telephone company’s network ends and where the premises wiring begins. It provides the point at which the inside wiring is connected to the telephone network. It is also known as a wiring distribution device.

Part Number 15-184-60 is an adaptor specifically designed for the sole use of attaching a protection device to the network interface device, such as the CAC-200. The adaptor is screwed to the NID and the protection device is bolted to the adaptor. The adaptor is made of molded plastic and will be imported with two screws, washers, and a bolt.

Part Number 15-200-68 is a module consisting of an RJ-11 plug and jack mounted on a plastic bridge and is the demarcation point for the NID. The bridge has four screw terminals to which the telephone customer’s wiring is connected. The line cord from the bridge is connected to the RJ-11 jack and the jack is connected to a station protector. Unless there is a problem with the line, the line cord is always connected to the RJ-jack. In the event of a line problem the line cord would be disconnected from the jack and the premise’s telephone would be connected in its place to determine the source of the problem.

The applicable subheading for the protected terminating device (PTD) (Part Number PTD-3L1H), and network interface device (NID) (Part Number CAC-200), will be 8517.50.5000, Harmonized Tariff Schedule of the United States (HTS), which provides for “Other apparatus, for carrier-current line systems or digital line systems, Other: Telephonic”. The rate of duty will be free.

You suggest subheading 8517.90.52 as the classification for the adaptor (Part Number 15-184-60) and module assembly (Part Number 15-200-68). Subheading 8517.90.52 provides for “Parts: Other: Parts, including face plates and lock latches, for printed circuit assemblies: For telephonic apparatus: Other. However, neither Part Number 15-184-60 nor Part Number 15-200-68 is a part for a printed circuit assembly. Part Number 15-184-60 is an adaptor for attaching a protection device to a network interface device. Part Number 15-200-68 is a module to which telephone wiring is connected. Both of these items qualify for classification as “Parts for telephonic apparatus” under subheading 8517.90.64.

The applicable subheading for the adaptor (Part Number 15-184-60) and module assembly (Part Number 15-200-68), will be 8517.90.6400, Harmonized Tariff Schedule of the United States (HTS), which provides for “Parts: Other: Parts, Other: 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 646-733-3015.


Robert B. Swierupski

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