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NY N025894

May 8, 2008



TARIFF NO.: 8517.70.0000

Mr. Paul Nielson
Manager Import/Export Compliance & Logistics PCTEL Inc.
471 Brighton Drive
Bloomingdale, IL 60108

RE: The tariff classification of a zinc top covers from Taiwan

Dear Mr. Nielson:

In your letter dated April1, 2008, you requested a tariff classification ruling.

The merchandise subject to this ruling is zinc top covers. They are identified in your letter as part numbers ATB-2073, ATB-2075 and ATB-2076. The zinc top covers, which are cast, machined and painted, are components of various antenna models that are used in voice, information and other data (VID) applications. These zinc top covers is integral to the assembly of the finished antenna.

One of the primary components of a finished VID antenna is an element called a radiator. The radiator is used to secure the antenna to a fixed object (the mount). The zinc top covers are designed to attach to the radiator element, thus becoming a part of the finished antenna. The zinc top covers are integral, constituent components of the finished VID antenna because, in the absence of a zinc top cover, the finished VID antenna, although it would technically still function as an antenna, would be incapable of operating in frequencies that a finished VID antenna’s specifications require. Additionally, the zinc top covers also serve to protect the radiator element and its connection to the mount. As such, the zinc top covers are parts of a VID antenna.

A sample of a zinc top cover (part number ATB-2073) and a sample of a radiator element (part number ACS-2200), which is not the subject of this ruling, was furnished allowing this office to see how the radiator element and the zinc top cover fasten together. The zinc top cover has a threaded screw hole to which one end of the radiator element fastens via its threaded extension. The samples are being returned to you as per your request.

The applicable subheading for the zinc top covers (part numbers ATB-2073, ATB-2075 and ATB-2076) will be 8517.70.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Other apparatus for transmission or reception of voice, images or other data, including apparatus for communication in a wired or wireless network(such as a local or area network): Parts.” 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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