The tariff classification of an IP Encapsulator, a DVB Reference from France and a Two-Way Satellite Simulator from Israel

NY G86395 February 20, 2001 CLA-2-85:RR:NC:MM:109 G86395 CATEGORY: Classification TARIFF NO.: 8517.50.9000; 8525.10.3015; 9030.40.000 Mr. Paul Vroman Danzas AEI 2660 20Th Street Port Huron, MI 48060 RE: The tariff classification of an IP Encapsulator, a DVB Reference from France and a Two-Way Satellite Simulator from Israel Dear Mr. Vroman: In your letter dated January 9, 2001, you requested a tariff classification ruling on behalf of Spacenet, Inc. of McLean, Virginia. The merchandise is described in your letter as an IP Encapsulator, a DVB Reference and a Two-Way Satellite Simulator. They are described as follows: IP Encapsulator – is a rack-mounted specialized computer used to encapsulate IP (Internet Protocol) data packets into a DVB (Digital Video Broadcasting) compliant transport stream outputting the data rate with a high speed (usually up to 70Mbps). This equipment is part of the “Skyblaster” hub and is connected in front of the outbound modulator. It provides high-speed connectivity to the Internet. It allows the hub to fill an entire satellite transponder with IP data, resulting in a reduction in the amount of equipment needed in a satellite head end. An important benefit of the IP Encapsulator is the system’s optimized data handling architecture, designed to minimize latency and increase overall system performance. DVB-S (Digital Video Broadcasting) Reference Receiver VM-0186-00 – is a rack-mounted demodulator including forward error connection fully compliant with DVB-S specifications. It is part of the receive chain of the “Skyblaster” hub and is connected in front of the receiver cage. It provides monitoring functions, such as carrier frequency offset, channel bit error rate, C/N estimation and other dynamic parameters. It serves as a reference for the signal to be sent for direct broadcast video over the satellite. It is in fact a complete circuit board that serves as demodulator for the transmission of a direct video broadcast signal via a satellite. Two-Way Satellite Simulator GL5311 – is a rack-mounted electronic device used in connection with a “Skyblaster” hub to simulate the satellite path as in a real transmission. It is used “ for testing any new “Skyblaster” hubs or for routine maintenance of the hub equipment”. It is used “before a real transmission occurs”. It is also “used for troubleshooting a satellite transmission chain without having a real connection to the satellite”. It could be considered a highly specialized signal generator, but the Customs Service considers signal generators used in electrical testing to be classified in HTS 9030, not 8543.20, per Headquarters Ruling Letter 963266, dated January 27, 2000. The applicable subheading for the IP Encapsulator 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: Other.” The applicable subheading for the DVB-S Reference Receiver will be 8525.10.3015, Harmonized Tariff Schedule of the United States (HTS), which provides for “Apparatus for the reception of television signals relayed by television satellite”. The rate of duty will be 1.8 percent ad valorem. The applicable subheading for the Two-Way Satellite Simulator GL5311 will be 9030.40.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for “other” instruments and apparatus for measuring or checking electrical quantities, specially designed for telecommunications”. 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