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NY N008245

April 2, 2007



TARIFF NO.: 8517.62.0050

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

RE: The tariff classification of an Alcatel URW Subrack 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 URW Subrack.

The descriptive literature submitted states that the Alcatel URW Subrack is a hybrid of optical, electronic, and mechanical systems that forms part of a submarine telecommunication system for use in transmission of aggregate data. The Alcatel URW Subrack is of an Alcatel generic design and includes features that allow the configuration of the unit to suit a given system.

The Alcatel URW Subrack can be equipped with different plug-in telecommunication units according to the requirements of the submarine transmission system. The transmission interface between the submarine telecommunication system and the inland network will be provided by other equipment.

The Alcatel URW Subrack houses equipment for amplifying the telecommunication signal when the length of the submarine system exceeds the capability of the transmission equipment working on its own. Examples of equipment that can be mounted are: The Alcatel Optical Post Amplifier, which is mounted in the transmitting terminal; the Alcatel Raman Pump, which is mounted in the receiving terminal; and the Alcatel Remote Pump Unit, which is mounted in the receiving terminal. Electrical interconnections between plug-in units are achieved via a multi-layer printed circuit backplane and all optical transmission connections are made through the front panels of the units. The backplane extends into an area above the plug-in units to allow front-access for connections from the subrack to other parts of the terminal equipment. The Alcatel subrack will always have two power supply units fitted at the right-hand side, and next to them the Alcatel generic subrack management unit. The other positions in the subrack will be filled with optional units chosen to provide the functions required by the system design. In some terminal stations more than one subrack may be needed to hold the number of functional plug-in units required.

The applicable subheading for the Alcatel Dispersion Compensation Subrack 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 pare 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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