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NY N008243

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 Remote Optically-Pumped Amplifier (ROPA) 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 Remote Optically-Pumped Amplifier (ROPA).

The descriptive literature submitted states that the Alcatel Remote Optically-Pumped Amplifier (ROPA) is inserted into an unrepeatered telecommunication system to maximize the operating distance across which the telecommunication cable can function without the need for submerged repeater units. The telecommunication terminal station at each end of the cable span (land-based) controls the erbium-doped fiber amplifier modules within the ROPA. The ROPA is placed close to the receiving terminal to optimize, through preamplification, the aggregate data signal ahead of the receiver in the terminal station.

The underwater Jointing Box Housing and cable terminating arrangements can accommodate amplifier modules up to eight traffic-carrying fiber pairs, and are compatible with all types of Alcatel cable. The Jointing Box Housing is designed to allow laying, recovery, and re-laying in a submerged environment with no degradation in mechanical, optical, or electrical performance. The Jointing Box Housing can terminate all lightweight and armored cable designs, with load transfer through a flexible coupling. The tensile and torsional strengths of the housing are several times greater than that of the highest strength cable. The jointing box design prevents seawater contact with the housing steel surface, thereby eliminating metal wastage and hydrogen generation through galvanic corrosion and magneto-hydrodynamic effects. In addition, armored cables anchoring technique isolates the anchoring of the armor steel wires from seawater, thereby avoiding potential corrosion close to the ROPA.

The internal assembly includes a try assembly housing erbium-doped fibers, isolators, and excess fiber length as necessary to realize the connections to the line cable. High voltage insulation is maintained between the internal unit and the ROPA housing by a polyethylene liner.

The applicable subheading for the Alcatel Remote Optically-Pumped Amplifier (ROPA) 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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