The tariff classification of a network edge device from China

N303820 April 23, 2019 CLA-2-85:OT:RR:NC:N2:209 CATEGORY: Classification TARIFF NO.: 8517.62.0090 George Tuttle Tuttlelaw 1100 Larkspur Landing Circle, Suite 385 Larkspur, CA 94939 RE: The tariff classification of a network edge device from China Dear Mr. Tuttle: In your letter dated April 5, 2019, you requested a tariff classification ruling on behalf of your client, Silicom Connectivity Solutions Inc. The item concerned is referred to as the Silicom vE-CPE (AT&T V150 XS) “network edge device”. This item provides a point of entry into an enterprise or a service provider’s core network to virtually control “Customer Premises Equipment” (CPE). An edge device is hardware that resides at the boundary between two networks. Edge devices can fulfill a variety of roles depending on what type of device they are, but they essentially serve as network entry (or exit) points. Common functions of edge devices may include the transmission, routing, processing, monitoring, filtering, translation and storage of data passing between networks. Edge devices are used by enterprises and service providers to connect with CPE. As imported, the Silicom vE-CPE (AT&T V150 XS) cannot perform the function of a “router” or a network “switch” because the device does not include such software programing or applications. The device is essentially a generic Intel based computer that can run different applications and perform different functions based on the installed program choice of the user. When configured, Silicom’s vE-CPE is used to interface with a customer’s large variety of installed hardware, varying bandwidths and profiles, decreasing the need to send technical support to a site for the reconfiguration of installed equipment. The Silicom vE-CPE (AT&T V150 XS) incoprtaes modular hardware architecture that allows a user to mix and match LAN and WAN management and modules to conform to a customer’s requirements. It includes expansion slots for PCIe, mPCIe, USB 2.0 and SIM card (for Wi-Fi), M.2 slots for USB 3.0, SATA and SIM card (for LTE or storage), PCIe Gen3 Expansion slot, network modules and management module expansion slots. The applicable subheading for the Silicom vE-CPE (AT&T V150 XS) “network edge device” will be 8517.62.0090, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Telephone sets, including telephones for cellular networks or for other wireless networks; other apparatus for the 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 area network), other than transmission or reception apparatus of heading 8443, 8525, 8527 or 8528; parts thereof: 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 area network): Machines for the reception, conversion and transmission or regeneration of voice, images or other data, including switching and routing apparatus: Other.” The general 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 the World Wide Web at https://hts.usitc.gov/current. 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 Steven Pollichino at steven.pollichino@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division