CLA-2-85:OT:RR:NC:N1:109

Ms. Sylvia Bertolani
Atty in Fact
CEVA International
2190 Hanson Way
Woodland, Ca 95776

RE: The tariff classification of Tower Mounted Amplifiers (TMAs) and Multiple Carrier Power Amplifiers (MCPAs) from Thailand

Dear Ms. Bertolani:

In your letter dated April 8, 2011, you requested a tariff classification ruling on behalf of your client, Powerwave Technologies, Inc.

The merchandise subject to this ruling is Tower Mounted Amplifiers (TMAs) and Multiple Carrier Power Amplifiers (MCPAs). The TMAs are identified within your submission as Part # Series LGP215nn and 010-11183-02nn. The MCPAs are identified within your submission as Part # Series G3L-1829-120 and G3L-850-160. The essential function of the TMAs and the MCPAs is to receive and transmit (not convert) radio frequency signals in a wireless telecommunication network. They are components of the wireless network infrastructure and are specifically designed and dedicated for this use. TMAs and MCPAs are sold to both cellular operators as well as base station manufacturers and used in public safety and commercial deployments worldwide.

The TMAs are identified within your submission as Part # Series LGP215nn and 010-11183-02nn. TMAs, also known as Mast Head Amplifiers, are low noise amplifiers used in mobile communication networks to improve the quality of the base station’s communication. They reduce the noise figure and improve the base station’s receive sensitivity. The main components of a TMA are passive RF filters, low noise amplifier and supporting digital components. The TMA is mounted to the mast, a few feet from an antenna, of a mobile phone tower. The TMA is connected to the antenna via a jumper cable. The signal picked up by the antenna is amplified by the TMA before being connected to the feeder cable where it is attenuated. A weak signal picked up by the antenna does not disappear in noise after passing the feeder cable. The base station transceiver receiver sensitivity is increased and a balance between uplink and downlink is achieved. The TMA is connected to the base transceiver station via the main feeder and Current Injector (CIN). The TMA needs a CIN and Power Distribution Unit (PDU) to operate. The CIN and PDU are external separate units. The PDU provides the DC power for the TMAs. The CIN injects the DC voltage from the PDU onto the RF coax cable. The TMA internally extracts the DC voltage to power up and operate its internal amplifier circuits. The CIN and PDU are not imported with the TMA.

The TMA reduces noise figure (filters out distorted signals) by introducing gain and a low noise figure at the top of the tower so any insertion loss from the TMA to the base station will affect noise figure minimally, thus improving base station sensitivity. The TMA is a receive amplifier that helps reduce the system noise figure, thereby improving the base station’s sensitivity. It boosts the signal before degradation. It takes a signal from the cell phone, on-air, and amplifies it so the base station gets a clearer signal. The result of the improved system noise figure and sensitivity is reduced number of dropped calls, improved voice quality, increased battery life, improved system sensitivity, improved coverage, less cell sites needed for same coverage, reduced radiation, and increased cell capacity for CDMA based systems.

The MCPAs are identified within your submission as Part # Series G3L-1829-120 and G3L-850-160. MCPAs are also used with wireless communication base stations. There function is similar to the TMA. However, MCPAs are ultra-linear feed forward power amplifiers. They support multiple air interfaces simultaneously. An MCPA increases the output power from the base station transceiver so the cell phone receives a stronger signal, thus increasing the operating area of the cell site. The main components of an MCPA are passive RF filters, low noise amplifier, RF power components and AC to DC power rectifiers.

The MCPA is powered by a 24v DC supply from an internal rectifier that converts AC voltage to DC. The MCPA provides the base station operator with additional RF downlink (base station transmit) gain to help overcome coverage gaps in the wireless network. MCPAs also allow the service provider to reduce the number of base station deployments required and increased overall network capacity.

The applicable subheading for the Tower Mounted Amplifiers (TMAs) and the Multiple Carrier Power Amplifiers (MCPAs) will be 8517.69.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for "Other apparatus for transmission or reception of voice, images or other data, including apparatus for communication in a wired or wireless network (such as a local or wide are network): Other." The rate of duty will be free.

Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.

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