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NY K82013

January 9, 2004
CLA-2-84:RR:NC:1:110 K82013


TARIFF NO.: 8471.80.9000

Mr. Don Wallace
Carson Customs Brokers USA
P.O. Box 653
Blain, WA 98230

RE: The tariff classification of communication converters and network interface card from Canada.

Dear Mr. Wallace:

In your letter dated December 15, 2003 on behalf of your client Power Measurement LTD., you requested a tariff classification ruling.

The merchandise under consideration is two communication converters and a network interface card for use with equipment manufactured by Power Measurement LTD. Power Measurement LTD manufactures instruments for measuring power consumption and usage. The equipment offers revenue-certified power, energy, demand, time-of-use metering and true power quality analysis. From the information provided with your request, the instruments manufactured by Power Measurement LTD support the Electronics Industry Association (EIA) standard RS485 Data Interface. RS485 is a specialized interface that would not be considered standard equipment on today’s home personal computer (PC). The more common data interface standard in today’s PCs is the RS232. RS232 signals work well in point to point communications at low data transmission rates limited to one or two hundred feet, whereas the RS485 signals will perform well at extended lengths of up to 4000 feet. The RS232 may be converted to RS485 with a simple interface converter.

The two converters at issue for this ruling request are the COM32 and COM128 communication converters. The COM32 and COM128 communication converters allow the connection of Power Measurement LTD’s equipment from their EIA standard RS485 port to the RS232 port. The COM32 and COM128 converts signals from the measuring instruments into a format usable by an automatic data processing (ADP) machine. This connection allows bi-directional communication between the power measuring instruments and a number of remote computers.

The COM32 can connect directly to a PC with its RS232 port or via a modem. The RS485 communications port on the COM32 allows connections to multiple devices. Up to 32 devices can be connected onto the single RS485 port. The COM128 also connects directly to a PC with its RS232 port or via a modem and is used to interface a single RS232 communication port to up to four RS485 communication ports. This configuration allows connections of up to 128 different devices.

The network interface card is the 7700 ION Xpress Card. This is a communication card for the Power Measurement LTD 7700 ION Power Meter. This network interface card allows the 7700 ION Power Meter to communicate over a computer network using standard network protocols.

The Explanatory Notes (ENs) of the Harmonized Tariff System (HTS) provide guidance in the interpretation of the Harmonized Commodity Description and Coding System at the international level. EN 84.71 (I)(D) states in part: “Apart from central processing units and input and output units, examples of other units include(5) Signal converting units. At input, these enable an external signal to be understood by the machine, while at output, they convert the output signalsinto signals which can be used externally.” The COM32, COM128 and 7700 ION Xpress Card appear to meet the requirements of this category.

The applicable subheading for the COM32, COM128 and the 7700 ION Xpress Card will be 8471.80.9000, Harmonized Tariff Schedule of the United States (HTS), which provides for “Automatic data processing machines and units thereofOther units of automatic data processing machines: Other: Other.” The general 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 Eileen S. Kaplan at 646-733-3016.


Robert B. Swierupski

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