CLA-2-85:RR:NC:1:112 L80625

Mr. Robert J. Pisani
Pisani & Roll
Attorneys at Law
1717 K Street NW, Suite 600
Washington, D.C. 20036

RE: The Tariff Classification of an ASN OALC 6 Submarine Telecommunication Cable. Country of Origin not stated.

Dear Mr. Pisani:

In your letter dated October 12, 2004,on behalf of Alcatel Submarine Networks (ASN), you requested a tariff classification ruling.

Based on submitted descriptive literature and technical document, the ASN OALC 6 Submarine Telecommunication Cable is a hybrid of optical and mechanical operations that form part of a submarine telecommunication system for use in transmission of aggregate data. The ASN cable design can accommodate up to 48 fiber pairs. The optical fibers are housed in a jelly-filled (non-hygroscopic filling compound) steel tube surrounded by further layers of steel wires that provided tensile strength. This steel tube is insulated with a layer of polyethylene to form the telecommunication cable. The telecommunication cable is designed to protect and facilitate the optical fiber transmission path during operation (carry the signal), during installation (laying and burial at sea), and recovery operations.

The applicable subheading for the ASN OALC 6 Submarine Telecommunication Cable will be 8544.70.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for optical fiber cables. 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 Richard Laman at 646-733-3017.


Robert B. Swierupski
National Commodity
Specialist Division