CLA-2-85:RR:NC:MM:109 J87637

Ms. Donna M. Dion
APC Corporate Import/Export Manager
American Power Conversion Corporation
P.O. Box 278
132 Fairground Road
West Kingston, RI 02892

RE: The tariff classification of a Network Management Card (AP9617) from India

Dear Ms Dion:

In your letter dated July 21, 2003, you requested a tariff classification ruling.

The merchandise is described in your letter as a Network Management Card (AP9617). The AP9617 Network Management Card is a full-featured, robust power management product designed to work with Network Management Systems. 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.

A sample of the Network Management Card (AP9617) was submitted to this office. The sample consisted of an APC printed circuit assembly (labeled AP9617 Network Management Card EM/MDM), a cable with a connector on each end, an APC Network Management Card utility CD, and an Installation and Quick Start Manual. 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 AP9617 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 (AP9617) 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