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NY R02055

June 20, 2005

CLA-2-85:RR:NC:N1:109 R02055


TARIFF NO.: 8517.30.5000

Mr. Michael E. Roll
Pisani & Roll
1875 Century Park East
Suite 600
Los Angeles, CA 90067

RE: The tariff classification of an “Alcatel Optical (Transmission) Channel Protection (OCP)” from an unspecified country

Dear Mr. Roll:

In your letter dated May 27, 2005 you requested a tariff classification ruling on behalf of your client Alcatel Submarine Networks (“ASN”).

This ruling concerns the classification of an “Alcatel Optical (Transmission) Channel Protection (OCP).”

The descriptive literature submitted states that the “Alcatel Optical (Transmission) Channel Protection (OCP)” is a hybrid of optical, electronic, and mechanical systems that form part of a telecommunication system for use in transmission of aggregate data (speech & data). It operates within the telecommunication system by switching the paths or channel(s) of the aggregate data being transmitted. The submitted literature does not contain any evidence that the “Alcatel Optical (Transmission) Channel Protection (OCP)” contains any lenses.

The point-to-point and multipoint wavelength division multiplexing (WDM) telecommunications links can be protected using an optical (transmission) protection scheme by switching the transmission channel(s). The OCP supports transmission (optical) channel protection in a 1+1 single ended client mode. The same protection unit can also be used for ring architectures and in both cases the whole optical (transmission) telecommunication link is protected, including the transponders. The OCP is telegraphic switching apparatus because it enables protected transmission of speech & data.

The “Alcatel Optical (Transmission) Channel Protection (OCP)” is of an Alcatel generic design and includes features that allow the configuration of the “Alcatel Optical (Transmission) Channel Protection (OCP)” to suit a given system.

The applicable subheading for the “Alcatel Optical (Transmission) Channel Protection (OCP)” 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 Hackett at 646-733-3015.


Robert B. Swierupski

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