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NY N017213

October 3, 2007



TARIFF NO.: 8517.62.0050

Mr. Ram J. Arvikar
VP Quality & Corp. Compliance
Vectron International
267 Lowell Rd.
Hudson, NH 03051

RE: The tariff classification of a Vectron electronic timing module

Dear Mr. Arvikar:

In your letter dated September 17, 2007 you requested a tariff classification ruling.

The merchandise subject to this ruling is a Vectron electronic timing module. A photocopy of the module was furnished and bears the markings C4481-0062 20.000MHz S/N 09043-0009. This is a populated printed circuit board (aka printed circuit assembly). The substrate is a printed circuit board (PCB) usually made of epoxy-glass material and is insulating in nature with conductor patterns (copper). The finish on the pattern is usually gold. The substrate consists of multiple layers with each layer separated by insulating epoxy-glass, with conductor patterns created by etching on each layer, which are interconnected through “vias” where needed. Other than the conductor traces, there are no patterned passive devices on the substrate, as would be found on insulating substrates, such as ceramic substrates on which a thin or thick film circuit is formed. The Vectron electronic timing module is not a hybrid integrated circuit because, in accordance with Note 8 (b) (ii) to Section XVI, although active elements (diodes, transistors, monolithic integrated circuits, etc.) were obtained by semicoinductor technology, passive elements (resistors, cspacitors, inductances, etc.) were not obtained by thin or thick film technology, as Note 8 (b) to Section XVI describes.

This timing module is centrally located in a telephone switching central office. It provides timing control and distribution with the local central office, but its timing distribution may feed network elements that drive data signals to other central offices. The signals generated from the timing module generate electrical current. In essence, the Vectron timing module is a timing generator or synchronous signal unit involved in the timing of transmission in a wide area network (WAN).

The applicable subheading for the Vectron electronic timing module 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 general 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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