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NY L80751

December 1, 2004

CLA-2-85:RR:NC:1:112 L80751


TARIFF NO.: 8543.89.9695

Matthew K. Nakachi
Law Office of George R. Tuttle
3 Embarcadero Center
Suite 1160
San Francisco, CA 94111-4044

RE: The tariff classification of a central gateway module from the Philippines

Dear Mr. Nakachi:

In your letter dated September 27, 2004, you requested a tariff classification ruling on behalf of Conti TEMIC Microelectronic GmbH of Germany.

The item concerned is the Central Gateway module (see below). it is a covered circuit assembly board which contains a 30 MHz microprocessor, digital memory and embedded software. Its purpose is to accurately direct electronic information between several electronic Controller Area Networks (CANs) which exist within the electrical system of a Daimler-Chrysler vehicle; this allows vehicle systems to operate properly.

You suggest classification of this item within HTSUS 8517.50 which provides for “Electrical apparatus for line telephony or line telegraphy ...: Other apparatus for carrier-current line systems or for digital line systems ... “. Although the Central Gateway module is an electrical apparatus, it is designed for specific use with an individual vehicle’s Central Area Networks (CANs) and its purpose is to communicate, route and deliver electronic data solely between those in-vehicle electronic networks. Since the transmission of the Central Gateway module’s data is limited to the confines of a single vehicle, it is not classifiable within Heading 8517 as that Heading is intended to provide for “long haul transmission” of data.

The applicable subheading for the Central Gateway Module N93 will be 8543.89.9695, Harmonized Tariff Schedule of the United States (HTS), which provides for Electrical ... apparatus, having individual functions, not specified or included elsewhere ... : Other ... apparatus: Other: Other: Other: Other: 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 Richard Laman at 646-733-3017.


Robert B. Swierupski

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