NY 815902: The tariff classification of Netrunner Integration Routers from Malaysia

Native CBP ruling rendition. Applicability is fact-specific; modification/revocation relationships and original publisher date are retained. Publisher sentinel year0001 means unknown date, not a historical legal adoption.

                            NY 815902

                            October 20, 1995
                           

CLA-2-84:R:N1:110 815902  

CATEGORY:  Classification

TARIFF NO.: 8471.99.1500  

Mr. Dennis Heck
Tower Group International, Inc.
2400 Marine Avenue
Redondo Beach, CA 90278-1103

RE:  The tariff classification of Netrunner Integration Routers
     from Malaysia

Dear Mr. Heck:

     In your letter dated October 13, 1995, on behalf of Micom
Communications Corp., you requested a tariff classification
ruling.

     The merchandise under consideration involves four models of
integration routers which are basically free standing units that
allow for multiprotocol transmissions to be sent across wide area
network (WAN) lines.  The four models include the following:
Netrunner 50E data/voice internetwork feeder/router; Netrunner
100E Data/voice Internetwork Node; Netrunner 200E Integration
Router, and Netrunner 500ET Integration Router.

     These Netrunner units are high performance IP/IPX routers,
with hardware data compression and central point of control. 
Voice digitization and compression is performed by using 20 MIPS
digital signal processors (DSP) in order to reduce WAN bandwidth
requirements.  The Netrunner series is Novell certified and
integrates Ethernet LAN traffic with free legacy data traffic and
toll-free voice and fax.  This is done by compression of all
information on one end (data, voice, LAN), overlaying it on the
existing network, and  decompressing it on the other end.   The 
mainboards of these various models of  Netrunner units contains
various configurations of the Z80-Zilog microprocessor, and  all
units contain various ROM's of program memory from .5MB to 765KB
EPROM and 32KB of non-volatile RAM.  All four models possess I/O
capability.

     Noting Legal Note 5 (B) to Chapter 84 of the  HTS, these
various models of routers appear to meet the definition of  a
"unit" of an ADP system.  They control and process information
exchange within the framework of a network, and are used to
interconnect the CPU to other units or ADP machines, thereby
serving "control" and "adaptor" functions.

     The applicable subheading for the four models of Netrunner
routers will be 8471.99.1500, Harmonized Tariff Schedule of the
United States (HTS), which provides for control or adaptor units.
The rate of duty will be free.   

     This ruling is being issued under the provisions of Section
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 Art
Brodbeck at 212-466-5490.



                                        Sincerely,



                                        Roger J. Silvestri
                                        Director
                                        National Commodity
                                        Specialist Division