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NY N007340

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 R1 Passive Tilt Equaliser (PTEQ) Telecommunication Equipment” 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 (ASN).

This ruling concerns the classification of the “Alcatel R1 Passive Tilt Equaliser (PTEQ) Telecommunication Equipment”.

The descriptive literature submitted states that the “Alcatel R1 Passive Tilt Equaliser (PTEQ) Telecommunication Equipment” is a hybrid of optical and mechanical systems that forms part of a submarine telecommunication system for use in transmission of aggregate data. The Alcatel R1 Passive Tilt Equaliser is of an Alcatel generic design and includes features that allow the configuration of the Alcatel R1 Passive Tilt Equaliser to suit a given telecommunication system requirement.

The “Alcatel R1 Passive Tilt Equaliser (PTEQ) Unit is inserted in a submerged telecommunication system where an equalization of the residual gain/wavelength slope, which accumulates when the signal is transmitted through a chain of submerged amplifiers, is required to optimize the overall system transmission.

The PTEQ is modular in construction. Modules are configured in pairs on a common internal assembly (boat), several boats can be incorporated to operate with up to 8 fibre pairs. The PTEQ passes power feed current without any significant voltage drop.

The applicable subheading for the “Alcatel R1 Passive Tilt Equaliser (PTEQ) Telecommunication Equipment” 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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