The tariff classification of a ZiPhone 3 CRM Phone System from an South Korea

NY R04465 July 27, 2006 CLA-2-85:RR:NC:MM:109 R04465 CATEGORY: Classification TARIFF NO.: 8517.19.8070 Mr. Richard B. George CEO Airedale Technology Associates, Inc. 11333 Ironton Street Henderson, CO 80640 RE: The tariff classification of a ZiPhone 3 CRM Phone System from an South Korea Dear Mr. George: In your letter dated July 24, 2006, you requested a tariff classification ruling. The merchandise subject to this ruling is a ZiPhone 3 CRM Phone System. It is described within your letter as a desktop communications device that resembles a business type telephone, but integrates into a computer environment via a USB cable. Its size and features make it a scalable Computer Telephony Integration (CTI) solution for a variety of environments to include homes, small businesses, and even large call centers. The ZiPhone 3 CRM Phone System can connect to both a telephone line and a computer via a USB cable. The connection to the phone line allows the device to access the Public Switched Telephone Network (PSTN). The connection to the computer enables almost full control over the phone functionality. When the ZiPhone 3 CRM Phone System is connected via a USB cable, it may receive its needed 5 volts of operating power from the computer. In addition, an alternating current (AC) to direct current (DC) power converter may be attached so that it can receive its required volts of operating power from AC. In this non-CTI capacity, the ZiPhone 3 CRM Phone System may be used as a stand alone telephone device and can be disconnected from the computer and still retain its PSTN functionality. In this latter capacity, the user can control the ZiPhone 3 CRM Phone by using the standard telephone push-buttons on the device’s keypad. For all intents and purposes, this is a single line push-button lined telephone with features, such as redial, mute, speakerphone, LCD display of call status, digital call recording and answering machine facility when connected to a computer. The applicable subheading for the ZiPhone 3 CRM Phone System will be 8517.19.8070, Harmonized Tariff Schedule of the United States (HTSUS), 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: Single line: Other.” 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 646-733-3015. Sincerely, Robert B. Swierupski Director, National Commodity Specialist Division