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NY N008238

April 2, 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 Fixed Filter Unit (FFU) from an unspecified country

Dear Mr. Roll:

In your letter dated March 12, 2007, you requested a tariff classification ruling on behalf of your client Alcatel Submarine Networks (ASN).

This ruling concerns the classification of an Alcatel Fixed Filter Unit (FFU).

The descriptive literature submitted states that the Alcatel Fixed Filter Unit (FFU) is a hybrid of optical, electronic and mechanical system that forms part of a submarine telecommunication system for use in transmission of aggregate data. The Alcatel Fixed Filter Unit (FFU) is of an Alcatel generic design and includes features that allow the configuration of the FFU to suit a given system.

The Alcatel Fixed Filter Unit (FFU) can be installed in the Alcatel Dispersion Compensation Subrack Telecommunication Equipment to perform equalization of the transmission (optical) signal. The Alcatel Fixed Filter Unit is located in the WDM telecommunication signal path at the receiving side of the system. The transmission (optical) noise from the system is band-limited by a band pass filter and a gain flattening filter (“GFF”) that equalizes the relative telecommunication channel power levels in the received WDM signal.

There are three variants of the Fixed Filter Unit available, each with a different GFF profile that may be installed depending on the system configuration. The three variants are: for equalization of telecommunication system tilt induced by Raman amplification using a Raman Pump; for equalization of telecommunication system tilt induced by remote amplification using a submerged amplifier and Remote Pump; for equalization of telecommunication gain tilt in a cascade of amplifiers and dispersion compensation units. The transmission connections are made by removable SC/APC type connectors.

The applicable subheading for the Alcatel Fixed Filter Unit (FFU) 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 M. Hackett at 646-733-3015.


Robert B. Swierupski

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