CLA-2-84:S:N:N1:110 880543
Mr. David I. Wilson
Arter & Hadden
1801 K Street, N.W., Suite 400K
Washington, D.C. 20006-1301
RE: The tariff classification of an "Iopro" asychronous
multiport board and an "Iolan" computer terminal server from the
United Kingdom
Dear Mr. Wilson:
In your letter dated November 12, 1992, on behalf of Chase
Research, Inc., you requested a tariff classification ruling.
The merchandise under consideration involves two models of
LAN equipment that are used in a local area network for
interconnecting terminals, printers, and modems.
The "Iopro" asynchronous multiport boards are installed
inside of a personal computer and provide eight or more serial
port connections for terminals, printers, and modems. Both the
"Iopro" and the "Iolan" operate in the Unix environment and use
the TCP/IP (telnet/rlogin) communications protocol to link
together various types of ADP equipment into LANs. The "Iopro"
is most often used with relatively simple computer systems such
as those found in doctors' or dentists' offices and small law
firms. The device consists of two components: 1. a stuffed
printed circuit board with an 80C186 chip operating at 16 MHz,
that fits into one of the expansion slots inside of a PC and 2.
one or more port "pods" that are external to the PC. The "pods",
which are physically joined together if there is more than one of
them, connect to the PC by means of an eight-foot cable. The
"Iopro" works by allowing a PC user to select options from a menu
that appears on the screen of the PC monitor. The execution of
the computer programs loaded into RAM enables the various forms
of ADP equipment on the LAN to communicate with each other and
thereby to process data according to users' commands.
The "Iolan" is a terminal concentrator subsystem that
features eight or sixteen RS232C asynchronous serial ports,
enabling terminals, printers, and modems to communicate over an
Ethernet backbone with other nodes or one or more host computer
system on the network. It incorporates a 16-bit 80C186 processor
running at 16 MHz which manages all on-board processing tasks.
This unit incorporates 1 Mb of RAM, and is most often used with
complex computer systems such as those found in banks, corporate
offices and large law firms. The "Iolan" uses electronic
circuitry and firmware basically similar to those used by
"Iopro", but in Iolan both the circuit board and ports are housed
together in a box entirely external to a PC.
Noting Legal Note 5 (B) to Chapter 84 of HTS, and recent HQ
ruling letter 952659 of October 7, 1992, these two devices appear
to be principally used to effectuate interconnection of the CPU
unit to other units or ADP machines, thereby serving "control"
and "adaption" functions.
The applicable subheading for the "Iopro" and "Iolan"
network units will be 8471.99.1500, Harmonized Tariff Schedule of
the United States (HTS), which provides for control or adapter
units. The rate of duty will be free.
This ruling is being issued under the provisions of Section
177 of the Customs Regulations (19 C.F.R. 177).
A copy of this ruling letter should be attached to the entry
documents filed at the time this merchandise is imported. If the
documents have been filed without a copy, this ruling should be
brought to the attention of the Customs officer handling the
transaction.
Sincerely,
Jean F. Maguire
Area Director
New York Seaport