CLA-2-85:RR:NC:MM:109 R02246

Mr. Hector Flores
Import& Export Supervisor
Advanced American Telephone
1143 SBC Center Parkway
San Antonio, TX 78219

RE: The tariff classification of an Expandable Broadband Telephone System and an accessory (cordless) handset from an unspecified country

Dear Mr. Flores:

In your letter dated July 8, 2005, you requested a tariff classification ruling.

The merchandise is identified in your letter as an Expandable Broadband Telephone System (Model IP 8100-2) and an accessory (cordless) handset (Model IP 811).

The Expandable Broadband Telephone System (Model IP 8100-2) is a 5.8 GHz Digital Spread Spectrum Frequency Hopping Technology lined telephone with 2 cordless handsets each with a recharging base station. The cordless handsets feature a caller ID display, a “hands-free” speakerphone, a 50 name and number phonebook directory, a 50 name and number caller ID history, a voicemail-waiting indicator, and a last 5 number redial button. The system, whose network capabilities include an integrated telephone adapter and router, built-in LAN and WAN ports, a WEB-based browser, security protection a firewall and VPN pass through, is capable of expansion of up to four cordless handsets (Model IP 811).

The accessory (cordless) handset (Model IP 811) is designed for use exclusively with the Model IP 8100-2 Expandable Broadband (Lined) Telephone System, enabling the system to expand up to four handsets with each system. The cordless handset has a recharging base station and features caller ID/call waiting, a “hands-free” speakerphone, V MODE™ to: transfer calls, conference an outside call or use the intercom feature between handsets, a 50 name and number phonebook directory, Tri-lingual prompts: English, Spanish, or French, a voicemail-waiting indicator, a belt clip, and One-Touch access to voicemail and feature setup.

The applicable subheading for the Expandable Broadband Telephone System (Model IP 8100-2) and accessory (cordless) handset (Model IP 811) will be 8517.11.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for “Electrical apparatus for line telephony or line telegraphy including telephone sets with cordless handsets and telecommunications apparatus for carrier-current line systems or for digital line systems…Telephone sets…Line telephone sets with cordless handsets.” The rate of duty will be free.

The applicable subheading for the accessory (cordless) handset (Model IP 811) will be 8525.20.9080, Harmonized Tariff Schedule of the United States (HTS), which provides for which provides for Transmission apparatus for radiotelephony, radiotelegraphy, radiobroadcasting or television, whether or not incorporating reception apparatus or sound recording or reproducing apparatus; television cameras; still image video cameras and other video camera recorders; digital cameras: Transmission apparatus incorporating reception apparatus: Other … Other. The rate of duty will be free.

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.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division