CLA-2-84:S:N:N1:110 811909
Mr. Anthony R. Pranses
Rudolph Miles & Sons, Inc.
4950 Gateway East
P.O. Box 11057
El Paso, Texas 79983
RE: The tariff classification of computer network interfacing
devices from Mexico.
Dear Mr. Pranses:
In your letter dated June 14, 1995, on behalf of Xircom
Inc., you requested a tariff classification ruling.
The merchandise under consideration involves ADP interface
devices which are known as the CE-10B2-MAU, the CEM-10BT-DAA,
and the PPX-03 models. These devices are terminated to
conductive cable rather than being housed in a single unit.
The CE-10B2-MAU and the CEM-10BT-DAA devices provide both
physical and data-link interfaces between a data network such as
an Ethernet Local Area Network (LAN) or the Public Switched
Telephone Network (PSTN) and a Xircom Network Interface Card
(NIC) installed inside a computer. The physical and data-link
interface functions include analog to digital and digital to
analog data conversion, and related activities. Although the
CEM-10BT-DAA does link a modem with a PSTN, it also provides
other functions including signaling network status to the host
computer through the attached Xircom NIC. Data transmission
between the CEM-10BT-DAA and the LAN occurs through the Xircom
Network Interface Card.
The model PPX-03 device performs electronic signal switching
under software control. It is directly attached to a computer's
parallel port interface, and facilitates the sharing of multiple
peripherals such as LAN interface devices, printers, and security
keys. This device includes internal digital logic that examines
the parallel data stream for indication to switch channels from
one port to another port.
Noting Legal Note 5(B) to Chapter 84 of the HTS, these
devices appear to be principally used to connect the central
processing unit to other units or ADP machines, thereby serving
"control" and "adaption" functions. Please note also
Headquarter's Ruling Letters 953205, 953921, and 957325 which
involved similar merchandise.
The applicable subheading for the models CE-10B2-MAU, the
CEM-10BT-DAA, and the model PPX-03 will be 8471.99.1500,
Harmonized Tariff Schedule of the United States (HTS), which
provides for control or adapter units for automatic data
processing machines. 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