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NY N007331

March 19, 2007



TARIFF NO.: 8517.62.0050

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

RE: The tariff classification of an “Alcatel R3 Branching Unit” from an unspecified country

Dear Mr. Pisani:

In your letter dated February 22, 2007, you requested a tariff classification ruling on behalf of your client Alcatel Submarine Networks.

This ruling concerns the classification of an “Alcatel R3 Branching Unit”.

The descriptive literature submitted states that the “Alcatel ASN R3 Branching Unit” is designed for telecommunications systems utilizing submerged equipment. The “Alcatel R3 Branching Unit” is a hybrid of optical, electronic and mechanical systems that forms part of a submarine telecommunications system for use in transmission of aggregate data. The “Alcatel R3 Branching Unit” is of an ASN generic design and includes features that allow the configuration of the “Alcatel R3 Branching Unit” to suit a given system. The “Alcatel R3 Branching Unit” provides a power switching capability to allow various telecommunications system powering configurations and has provision for latching of the sea earth connection so that the configuration can survive partial power-down of the system. Power switching facilities are achieved by including Alcatel Repeater-type amplifier electronics in one trunk fiber pair and/or one spur fiber pair. These amplifiers facilitate the execution of supervisory commands. Additional non-amplified fiber pairs can pass through the “Alcatel R3 Branching Unit.” The unit is designed to terminate three line telecommunications cables and provide the following functions: line current switching; sea earth connection; latching of the sea earth connection; and diversion of one or more fiber pairs to the spur terminal. These features allow the “Alcatel R3 Branching Unit” to be utilized in complex branched telecommunication systems.

The applicable subheading for the “Alcatel R3 Branching Unit” will be 8517.62.0050, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Machines for the reception, conversion and transmission or regeneration of voice, images or other data, including switching and routing apparatus: Other”. The rate of duty will be free.

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 Linda Hackett at 646-733-3015.


Robert B. Swierupski

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