The tariff classification of Dynamic Optical Networking System from an unspecified country

NY J80385 January 30, 2003 CLA-2-85:RR:NC:MM:109 J80385 CATEGORY: Classification TARIFF NO.: 8517.50.9000 Mr. Robert A. Wilkinson Senior Customs & Trade Advisor Livingston International Trade Services, Inc. 25300 Telegraph Road, Suite 250 Southfield, MI 48034 RE: The tariff classification of Dynamic Optical Networking System from an unspecified country Dear Mr. Wilkinson: In your letter dated December 17, 2002 you requested a tariff classification ruling, on behalf of Ceyba Inc., 450 March Road, Kanata, Ontario K2K 3K2. You requested the classification of a C420 Dynamic Optical Networking System. A Parts List in excessive of 5 items was also within your submission. We have not addressed the classification of any of those items because we are not certain as to whether you were seeking the classification of those parts. However, it is important to note that, ruling requests must be limited to a maximum of 5 items in total to be accepted. The items in a single request must be of the same class or kind. For example, a request concerning textile articles may not include items such as footwear. The outside of envelopes and packages should be annotated "Binding Ruling Request." The C420 Dynamic Optical Networking System is an optical communications networking system that optimizes long-haul and ultra long-haul transmission. The C420, which is a solution to wavelength routing, provides carriers with a scalable and dynamically controlled system that minimizes optical-electrical-optical (OEO) conversions. Embedded within this system is a dynamic transmission control (DTC). The DTC enables the C420 to function as a self-regulating optical line system by detecting changes in the network and making adjustments to maintain optimal performance. There are three Ceyba Network Element (NE) types that shape the C420 Dynamic Optical Networking System. They are Flexible WaveHubs, Line Amplifiers and Dynamic Amplifiers. The Flexible WaveHub is the core element of the C420 architecture. It performs optical amplification and also has the ability to consolidate, aggregate and terminate traffic channels. Its flexibility allows it to be configured as a terminal or multi-degree node where multiple fiber paths converge. The Ceyba transmission hierarchy is designed so that an entire band, sub-band or individual channels can be independently added, dropped or optically by-passed through multi-degree nodes. The Line Amplifer overcomes signal attenuation through the use of Erbium-Doped Fiber Amplifiers (EDFA) and optional counter-propagating Raman amplifiers. An Optical Spectrum Analyzer (OSA) is an optional component that may be used to measure power levels, Optional Signal to Noise Ratio (OSNR) and identify per channel fault isolation. The Dynamic Amplifier provides optical amplification, dispersion compensation and dynamic gain equalization. Gain tilt is controlled through the use of an OSA and a Dynamic Gain Equalization module (DGEQ) automatically adjusting and ensuring optimal OSNR. The applicable subheading for the C420 Dynamic Optical Networking System. will be 8517.50.9000, Harmonized Tariff Schedule of the United States (HTS), which provides for “Electrical apparatus for line telephony or line telegraphy, including line telephone sets with cordless handsets and telecommunication apparatus for carrier-current line systems or for digital line systems…Other apparatus, for carrier-current line systems or for digital line systems: Other: Other.” The rate of duty will be free. We are returning any related samples, exhibits, etc. If you decide to resubmit your request for those items whose classifications were not provided, please limit each request to 5 items and include the material pertaining to those items upon resubmission. 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