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NY M84353

July 14, 2006

CLA-2-85:RR:NC:1:110 M84353


TARIFF NO.: 8537.10.9070

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

RE: The tariff classification of a charge/contactor control unit, the country of origin was not stipulated.

Dear Mr. Roll:

In your letter dated June 6, 2006, on behalf of your client Alcatel Submarine Networks (ASN), you requested a tariff classification ruling.

The merchandise under consideration is the Alcatel Charge/Contactor Control Unit. The Charge/Contactor Control Unit is a replaceable modular unit measuring approximately 6 inches by 4 inches. From the information provided with your ruling request, the Charge/Contactor Control Unit is a component of ASN’s submarine Power Feed Equipment (PFE), a system designed to power undersea repeatered cable network systems. The Charge/Contactor Control Unit is designed to protect the circuitry within the PFE from excess current caused by faults on the control and monitoring circuits. This is achieved through a series of relays and a trickle charge circuit that limits the flow of electricity preventing a sudden inrush of current. As imported, the Charge/Contactor Control Unit consists of relays, active and passive components mounted on a printed circuit board assembly.

In your letter you suggest classification under subheading 8536.30.8000, Harmonized Tariff Schedule of the United States (HTSUS) as other apparatus for protecting electrical circuits. The Charge/Contactor Control Unit, however, is an aggregation of apparatus for switching (relays) and protecting electrical circuits and is properly classified under heading 8537, HTSUS.

The applicable subheading for the Alcatel Charge/Contactor Control Unit will be 8537.10.9070, HTSUS, which provides for “Boards, panels, consolesand other bases, equipped with two or more apparatus of heading 8535 or 8536, for electric control or the distribution of electricityFor a voltage not exceeding 1,000 V: Other: Other: Other.” The general rate of duty will be 2.7 percent ad valorem.

Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.

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 Thomas Campanelli at 646-733-3016.


Robert B. Swierupski

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