CLA-2-84:S:N:N1:110 880137

Mr. Donald L. Fischer
Horton, Whiteley & Cooper
1900 Embarcadero, Suite 201
Oakland, CA 94606

RE: The tariff classification of a Asante 1012 Controller from Taiwan

Dear Mr. Fischer:

In your letter dated October 10, 1992, on behalf of Asante Technologies, Inc., you requested a tariff classification ruling. The merchandise under consideration involves a model 1012 controller which is a modular, freely programmable communications processor that controls and monitors the interfacing of computers including the CPU to other data processing machines, or to groups of input or output units linked as local area network systems in a star configuration (where computers are connected to a central hub). It serves as the network manager that is responsible for overseeing the operations of the local area network and communicating managerial information to the network operator.

As a network manager, the 1012 incorporates a uPD703222-V25 microprocessor whose "superset" instruction execution units perform the four basic manager/control functions. Contained in an aluminum chassis designed to be free standing or mounted into an Asante card cage, the 1012's electrical components are mounted on a standard fiberglass PCB. The electrical components include a microprocessor which (in addition to a built-in power supply) features a 16-bit internal architecture and 8-bit external data bus; two LSI chips specifically dedicated to systemwide data collection; and working in conjunction with the data retrieval chips, 50 LED's which are dedicated for specific control tasks.

Noting Legal Note 5 (B) to Chapter 84 of the HTS, this controller would meet the definition of a "unit" of an automatic data processing machine. The principal function of this controller appears to be for the interconnection of the CPU unit to other units or ADP machines, thereby serving "control" and "adaption" functions. The applicable subheading for the AsanteHub 1012 controller 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.


Jean F. Maguire
Area Director
New York Seaport