The tariff classification of Model RYKS, a “key feature” printed circuit assembly used in the Toshiba Strata digital key electronic telephone system, from Japan

NY G82609 October 17, 2000 CLA-2-85:RR:NC:MM:109 G82609 CATEGORY: Classification TARIFF NO.: 8517.90.3600 Mr. Mitchell Neriah Customs Consulting Services 415 S. Prospect Avenue Suite 110 Redondo Beach, CA 90277 RE: The tariff classification of Model RYKS, a “key feature” printed circuit assembly used in the Toshiba Strata digital key electronic telephone system, from Japan Dear Mr. Neriah: In your letter dated September 21, 2000, you requested a tariff classification ruling on behalf of Toshiba America Information Systems, Inc. (TAIS). The Model RKYS is described in your letter as a “key feature” printed circuit assembly consisting of one monolithic digital CMOS gate logic “Hex Bus Buffer” integrated circuit (Toshiba I.C. Model TC74HC365AF), ten resistors, one capacitor, and three diodes, which are mounted on a rigid printed circuit and encased in a plastic insulated casing. The RKYS model is a printed circuit assembly used in the Toshiba Strata digital key electronic telephone system. The RKYS (printed circuit assembly) is an option feature key, which plugs directly into one of the boards within the Toshiba Strata digital key electronic telephone system. It allows the telephone system to activate features already stored in memory blocks on the processor board. These features include a Built-in Auto Attendant (AA), Automatic Call Distribution (ACD) and Software Management Information Systems (SMIS). Although the software for the AA, ACD and SMIS functions are stored on the processor boards, they cannot be accessed or function without the RKYS key. The RKYS activates the AA, ACD, and SMIS functions by receiving, modifying and sending a signal to the 16-bit data bus microprocessor I.C. on the RCTU processor board within the Toshiba Strata digital key electronic telephone system. The change in signal will direct the microprocessor I.C. to the correct RCTU memory address where the AA, ACD, and SMIS features are stored. The RKYS’s Logic Hex Bus Buffer I.C. directs the microprocessor I.C. to the correct memory address by sending an output signal, which changes the value of data bus D0, D1, D2 and D3. The change in these four data bus allows the microprocessor I.C. to locate the software already stored in the memory on the RCTU processor board. The applicable subheading for the Model RKYS (printed circuit assembly) will be 8517.90.3600, Harmonized Tariff Schedule of the United States (HTS), which provides for “Printed circuit assemblies: For telephonic apparatus: For switching or terminal 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 212-637-7048. Sincerely, Robert B. Swierupski Director, National Commodity Specialist Division