CLA-2-85:RR:NC:MM:109 B80467
Mr. Dick Stanhope
Traffic and Customs Mgr.
Microcom, Inc.
500 River Ridge Drive
Norwood, MA 02062-5028
RE: The tariff classification of analog and digital modem
adaptors from China
Dear Mr. Stanhope:
In your letter dated December 9, 1996, you requested a
tariff classification ruling.
The merchandise is described in your letter and in the
attached literature as analog and digital modem adaptors.
Additional information and clarification was obtained on January
9, 1997, in a telephone conference with Darryl Peterson, Design
Engineer, Microcom. These adaptors are printed circuit boards
(PCBs) that attach to the back plane of the ISPorte Managed Modem
Chassis. The ISPorte offers up to 64 data/fax modems in a
compact 19" rackmount design. The analog adaptor is used for
connecting each modem to a standard two wire analogue telephone
line. It converts from four wires to two. The PCBs are
populated with isolation transformers, resistors, capacitors, and
connectors (RJ11, RJ45). They do not contain any active
components within the meaning of Section XVI Additional U.S. Note
1, and are therefore, not considered a "printed circuit assembly"
for the purposes of that section. The digital adaptor is used
for connecting to digital T1 type lines. They contain active
components which convert the analog modem signals into a digital
signal for transmission over a T1 line.
The applicable subheading for the analog modem adaptors will
be 8517.90.6600, Harmonized Tariff Schedule of the United States
(HTS), which provides for "[e]lectrical apparatus for...line
telegraphy...[p]arts: [o]ther: [o]ther: [f]or telegraphic
apparatus." The rate of duty will be 4.7%.
The applicable subheading for the digital modem adaptors
will be 8517.90.4400, Harmonized Tariff Schedule of the United
States (HTS), which provides for "[e]lectrical apparatus
for...line telegraphy...[p]arts: [o]ther: [p]rinted circuit
assemblies: [f]or telegraphic apparatus." The rate of duty will
be 4.7%.
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 Eileen
S. Kaplan at 212-466-5673.
Sincerely,
Robert B. Swierupski
Chief, Metals & Machinery
Branch
National Commodity
Specialist Division