CLA-2-85:RR:NC:MM:109 L86236

Mr. Michael E. Roll
Pisani & Roll
1717 K Street NW
Suite 600
Washington, DC 20036

RE: The tariff classification of an “Alcatel 1320 NX Craft Terminal for Telecommunication Equipment” from an unspecified country

Dear Mr. Roll:

In your letter dated August 3, 2005, you requested a tariff classification ruling on behalf of your client Alcatel Submarine Networks.

This ruling concerns the classification of an “Alcatel 1320 NX Craft Terminal for Telecommunication Equipment.”

The descriptive literature submitted states that the “Alcatel 1320 NX Craft Terminal for Telecommunication Equipment” is a hardware product, which, at the time of importation, has software loaded (imbedded) onto it.

The Alcatel 1320 NX Craft Terminal is comprised of software (telecommunication information technology) installed onto a computer hardware platform and is developed specifically to manage Alcatel telecommunication equipment. The Alcatel 1320 NX Craft Terminal is of an Alcatel generic design and includes features that allow configuration of the Alcatel 1320 NX to suit a given Alcatel telecommunication system requirement.

The Alcatel 1320 NX Craft Terminal is designed to supervise telecommunication equipment, manage Network Elements (when the element manager is unable to perform this task) and offers a facility for local test and maintenance operations as it can be placed close to the equipment under test.

The applicable subheading for the “Alcatel 1320 NX Craft Terminal for Telecommunication Equipment” 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