CLA-2-85:RR:NC:MM:109 R00773

Mr. George R. Tuttle
Law Offices
George R. Tuttle
Three Embarcadero Center
Suite 1160
San Francisco, CA 94111

RE: The tariff classification of various AccessMax Transceivers and an Asymmetrical Digital Subscriber Line 6+6H Plug-in Card from China

Dear Mr. Tuttle:

In your letter received on August 30, 2004, you requested a tariff classification ruling on behalf of Advanced Fibre Communications (AFC).

This ruling concerns the classification of an AccessMAX T1 Transceiver (Non-line powering) (TIX-XCR), AccessMAX T1 HDSL Transceiver (PairGain) (T1HD-XCVR), AccessMAX Line-Powering T1 Transceiver (T1-XCVR), AccessMAX Bi-Directional Fiber-Optic Transceiver (FOB-XCVR) and Asymmetrical Digital Subscriber Line 6+6H Plug-in Card (ADSL 6+6H). You state in your letter that AccessMAX is AFC’s integrated multiservice access platform, or “IMAP”. AccessMAX provides for the delivery of voice, video and high-speed Internet/data, as well as any combination of narrowband, wideband and broadband service, anywhere in the network, over existing copper, fiber and wireless transport options. AccessMAX includes DMAX, UMC, EMAX and EMAXplus, and associated equipment, such as plug-in cards, test heads, remote telecom cabinets, and accessories.

The AccessMAX T1 Transceiver (Non-line powering) (TIX-XCR) plug-in card provides an indoor ANSI/T1 DSX-1 level interface, transmitting and receiving up to 24 DSOs of voice or data. The T1X-XCVR operates at the T1 rate of 1.544 Mbps and is intended for applications requiring interface to multiplexers or other co-located equipment.

The AccessMAX T1 HDSL Transceiver (PairGain) (T1HD-XCVR) provides a T1 rate interface, transmitting and receiving up to 24 DSOs (1.544 Mbps) of voice or data originating from either a T1 transceiver or plug-in cards in the AccessMAX shelf.

The AccessMAX Line-Powering T1 Transceiver (T1-XCVR) provides a T1 cable interface, transmitting and receiving up to 24 DSOs of voice or data originating from either the channel units in the Channel Bank Assembly (CBA) subscriber slots, another CBA T1 transceiver, or a digital carrier line unit in a digital switch. It operates at the ANSI rate of 1.544 Mbps with a receiver sensitivity of 36 dB.

The AccessMAX Bi-Directional Fiber-Optic Transceiver (FOB-XCVR) interfaces to one single-mode fiber span, transmitting and receiving voice or data originating from plug-in cards in the AccessMAX Channel Bank Assembly (CBA). The FOB-XCVR features a 1310 nm laser to support unrepeatered span lengths of up to 25 miles. Actual distance depends on application conditions.

The Asymmetrical Digital Subscriber Line 6+6H Plug-in Card (ADSL 6+6H) plug-in card delivers high-speed data service over twisted copper pairs using industry standard Discrete Multi-Tone (DMT) line coding technology. All six ports of the ADSL 6+6 full rate card support both POTS and ADSL, each can be provisioned to support ANSI T1.413 full rate, G.DMT, or G.Lite.

The applicable subheading for the AccessMAX T1 Transceiver (Non-line powering) (TIX-XCR), AccessMAX T1 HDSL Transceiver (PairGain) (T1HD-XCVR), AccessMAX Line-Powering T1 Transceiver (T1-XCVR), AccessMAX Bi-Directional Fiber-Optic Transceiver (FOB-XCVR) and Asymmetrical Digital Subscriber Line 6+6H Plug-in Card (ADSL 6+6H), will be 8517.50.9000, Harmonized Tariff Schedule of the United States (HTS), which provides for “Other apparatus, for carrier-current line systems or for digital line systems: Other: Telegraphic: Other.” 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.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division