CLA-2-85:RR:NC:MM:109 J81745

Ms. Karen A. Sousa
APC Senior Import Specialist
American Power Conversion Corporation
132 Fairground Road
West Kingston, RI 02892

RE: The tariff classification of a Network Management Card (AP9618) from India

Dear Ms. Sousa:

In your letter dated March 26, 2003, you requested a tariff classification ruling.

The merchandise is described in your letter as a Network Management Card (AP9618). Network Management Cards provide standards-based monitoring, Configuration, Control, and event handling for APC Uninterruptible Power Supplies (UPSs), and PowerChute remote shutdown for systems over a 10/100BaseT Network. The modules are integrated onto a single UPS SmartSlot Card and have features like a built in modem for dial in, out of band management and environmental management capabilities for infrastructure management.

The AP618 Network Management Card EM/MDM includes the analog modem that provides for the following out-of-band communications that feature Dial-out notifications for APC’s Remote Monitoring service (RMS) and Dial-in access to the Management Card’s Console Interface. Integrated Environmental Monitor features a temperature/humidity probe, two input contacts, and two-position output relay. In addition to the Environmental Monitor, an AP9618 Management Card can still monitor and manage an external Environmental Monitoring Unit or Environmental Monitoring Card.

A sample of the Network Management Card (AP618) was submitted to this office. The sample consisted of an APC printed circuit assembly (labeled AP918 Network Management Card EM/MDM), a cable (smart-signaling) with a connector on each end, an APC Network Management Card utility CD, and an Installation and Quick Start Guide. The APC Network Management Card utility CD is utilized to remotely interface and monitor the Management Card’s Console. Together these items are considered a set, with the AP9618 Network Management Card EM/MDM imparting the essential character. The sample is being returned to you as per your request.

The applicable subheading for the Network Management Card (AP9618) will be 8504.90.6500, Harmonized Tariff Schedule of the United States (HTS), which provides for “Electrical transformers, static converters (for example rectifiers) and inductors; parts thereof: Parts: Other: Printed circuit assemblies: Of the goods of subheading 8504.40 or 8504.50 for telecommunications apparatus.” 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.


Robert B. Swierupski
National Commodity
Specialist Division