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NY N008829

April 19, 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 Optical Post Amplifier Unit (OPA28C) from an unspecified country

Dear Mr. Roll:

In your letter dated March 22, 2007 you requested a tariff classification ruling on behalf of your client Alcatel Submarine Networks (“ASN”).

This ruling concerns the classification of an Alcatel Optical Post Amplifier Unit (OPA28C).

The descriptive literature submitted states that the Alcatel Optical Post Amplifier Unit (OPA28C) is part of a hybrid of optical and mechanical systems that forms part of a submarine telecommunication system for use in transmission of aggregate data (speech & data). The article is of an Alcatel generic design and includes features that allow the configuration of the PFE to suit a given system.

The Alcatel Optical Post Amplifier Unit (OPA28C) is unrepeatered and is used when there is a requirement for high power amplification of the transmitted communication signal before it is launched into a submerged telecommunication cable, i.e., submarine digital line.

The applicable subheading for the Alcatel Optical Post Amplifier Unit (OPA28C) 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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