CLA-2-85:OT:RR:NC:N1:109
Mr. Brett Ian Harris
Pisani and Roll LLP
1629 K Street, NW
Suite 300
Washington, DC 20006
RE: The tariff classification of the TBX3000A, network access device from China
Dear Mr. Harris:
In your letter dated May 8, 2015, you requested a tariff classification ruling on behalf of your client, Tektronix, Inc.
The item concerned is referred to as the TBX3000A. This hardware device is used in conjunction with a specific software program referred to as the TSL3000B (software is not being addressed in this ruling). Together these entities form the TekSmartLabTM system. The TekSmartLabTM system is a network-based instrument management solution for electronics teaching laboratories.
In a laboratory teaching situation a TBX3000A hardware device would be installed at each workstation to connect Tektronix and Keithley products (oscilloscopes, signal generators, digital multi-meters and power supplies) into a networked lab environment. The TBX3000A incorporates six USB ports for connecting to the various electronic instruments/machines. It also incorporates an Ethernet LAN port used to connect the device into the users network.
The TBX3000A is used to communicate with a lab server that has the TSL3000B software installed. Working together the TSL3000B software and the TBX3000A hardware device give instructors centralized control/access over fleets of laboratory instruments. The operator of the TSL3000B software is able to transmit data in the form of instrument configurations to the individual instruments plugged into the TBX3000A, as well as monitor performance data and configure settings which are transmitted back through the network by the TBX3000A to the TSL3000B enabled server. The TBX3000A does not store or execute any commands using internal flash memory; rather the unit operates in a similar manner to a router, directing the commands executed by the user of the TSL3000B software on the server to the TBX3000A device. The TBX3000A enables the transfer of data between the instruments that are connected to it and a centralized server/computer over a defined network.
The applicable subheading for the TBX3000A hardware device will be 8517.62.0050, 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: Machines for the reception, conversion and transmission or regeneration of voice, images or other data…: 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 Steven Pollichino at (646) 733-3008.
Sincerely,
Gwenn Klein Kirschner
Director
National Commodity Specialist Division