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NY N008250

April 13, 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 ASN SPC Communications Unit 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 ASN SPC Communications Unit.

The descriptive literature submitted states that the Alcatel ASN SPC Communications Unit is a replaceable unit in Alcatel’s Power Feed Equipment (“PFE”), 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 Single Wavelength Transponder is of an Alcatel generic design and includes features that allow the configuration of the unit to suit a given system.

The PFE design incorporates a number of ASN modular units, or parts, that support the telecommunications function of the overall PFE. These units are part of the ASN PFE and cannot be used independently of it or in other equipment, although they can be interchanged within the PFE cabinet as a spare or replacement for an existing unit. These parts allow the PFE to perform a telecommunication function by providing power to the system.

The Alcatel ASN SPC Communications Unit is a replaceable plug-in unit of ASN’s PFE. It acts as a communication interface between the PFE and ASN’s telecommunication system’s network management system. The SPC communicates with micro units in each power unit using an RS422 interface, and with the network management system using Ethernet. The unit measures 50mm x 260mm x 240mm.

The applicable subheading for the Alcatel ASN SPC Communications 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 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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