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NY R00695

August 25, 2004
CLA-2-85:RR:NC:MM:109 R00695


TARIFF NO.: 8517.30.5000

Mr. Michael John Mastroberti
Director of Import/Export Compliance
CIENA Corporation
1201 Wintersion Rd
C2, 2 East
Linthicum, MD 21090-2203

RE: The tariff classification of CIENA CoreDirector Intelligent Optical Core Switches from an unspecified country

Dear Mr. Mastroberti:

In your letter dated August 12, 2004, you requested a tariff classification ruling.

This ruling concerns the classification of CIENA’s CoreDirector and CoreDirector CI products. These products are core telecommunications switching equipment used by service providers to direct large volumes of phone and data traffic over fiber optic lines.

The descriptive literature submitted for the CIENA CoreDirector Intelligent Optical Core Switches describes these products as intelligent optical switching systems that have the ability to consolidate multiple optical network elements into a single platform, automate network operations, and improve network reliability.

CoreDirector switches are designed to rapidly deliver a wide range of differentiable, end-to-end optical capacity across the network with flexible protection options and maximum operational simplicity. These switches incorporate the functionality of Add/Drop Multiplexers (ADMs), digital cross-connects, and optical cross-connects in a single unit. The CoreDirector products offer two platforms that support both Synchronous Optical NETwork (SONET) and/or Synchronous Digital Hierarchy (SDH). CoreDirector switches provide up to 640 Gb/s of non-blocking switching in a single rack and support a mix of up to 64 x 10G, 256 x 2.5G, and 512 x 155/622M optical interfaces. These switches provide the flexibility to groom and switch network traffic in granularities ranging from entire wavelengths down to the individual STS-1s/VC-3s and also support SONET/SDH translation.

Your letter suggested HTS 8517.50.9000, which provides for “Other apparatus, for carrier-current line systems or for digital line systems: Other: Telegraphic” Other.” However, the CoreDirector and CoreDirector CI products are telecommunications switching equipment, classifiable within subheading 8517.30 as telegraphic (voice and data) switching apparatus.

The applicable subheading for the CIENA CoreDirector Intelligent Optical Core Switches will be 8517.30.5000, Harmonized Tariff Schedule of the United States (HTS), which provides for “Telephonic 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 646-733-3015.


Robert B. Swierupski

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