HQ 087868: Plastic Optical Fiber Printer Cable Fitted With Connectors And Signal Converters; Electrical Signals; Optical Signals

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.

                            HQ 087868

                        December 11, 1990

CLA-2  CO:R:C:G  087868  CMS

CATEGORY: Classification

TARIFF NO.: 8471.99.60
            8544.70.00
            9001.10.00

Mr. Ben Deahl
Customs Department
Traffic & Insurance Division
Mitsubishi International Corporation
520 Madison Avenue
New York, NY 10022

RE: Plastic Optical Fiber Printer Cable Fitted With Connectors
    And Signal Converters; Electrical Signals; Optical Signals

Dear Mr. Deahl,

     This is in response to your request dated August 14, 1990,
for a classification ruling on certain fiber optic printer
cable.  Our ruling follows.

FACTS:

     The merchandise is described in the product brochure as
RFC504 Fibre Optic Printer Cable.  The product is used to
connect standard IBM personal computers and standard computer
printers.

     The product consists of a length of high grade plastic
optical fiber cable fitted on each end with a signal converter
and electrical pin connector.  The lengths of cable are made up
of individually sheathed fibers and are imported in lengths
ranging from 25 to 100 feet.  The signal converter and electrical
connector on each end of the cable are incorporated in the same
housing.  The housings measure approximately 78mm x 52mm x 18mm.

     The signal converters transfer the electrical signals which
are output by the personal computer to optical signals which are
then transmitted through the fiber optic cables.  The optical
signals are converted back to electrical signals by the signal
converter on the printer end of the cable.  The signal converters
also transfer serial signals to parallel signals and then back to
serial signals at the printer end of the cable.

                               -2-

     The importer states that by transferring the signal from an
electrical medium to an optical medium, there is no interference
from electromagnetic radiation during transmission.  This, it is
stated, increases the quality of the signal and the distance a
particular computer may be located from a printer.

ISSUE:

     Is the merchandise classified in Heading 8544 as optical
fiber cables made up of individually sheathed fibers, in Heading
9001 as optical fiber cables other than those of Heading 8544,
or in Heading 8471 as machines for transcribing data onto data
media in coded form?

LAW AND ANALYSIS:

     Heading 8544 in pertinent part describes "optical fiber
cables, made up of individually sheathed fibers, whether or not
assembled with electric conductors or fitted with connectors".

     The Explanatory Notes to Heading 8544, p. 1404, provide that
"[w]ire, cable, etc., remain classified in this heading if cut to
length or fitted with connectors (e.g., plugs, sockets, lugs,
jacks, sleeves or terminals) at one or both ends".

     Heading 8544 describes fiber optic cables fitted with
connectors, but it does not describe such cables fitted with
connectors and signal converters.  The signal converters are not
"connectors".  The signal converters are active devices that
convert electrical signals to optical signals, optical signals
to electrical signals, serial signals to parallel signals, and
parallel signals to serial signals.

     The printer cables are composite articles consisting of
signal converters and fiber optic cables fitted with connectors.
The cables are not the type of merchandise classified as
"composite machines" pursuant to Section XVI Note 3.  The cables
are GRI 3(b) composite goods classified according to the
component which gives the article its essential character.

     The importer argues that the essential component in the
printer cables is the signal converter.  It is argued that the
fiber optic cable is distinguished from standard electrical cable
because electrical cable is subject to interference from
electromagnetic radiation.  The fiber optic cable, however,
transmits through an optical medium and is not subject to such
interference.  It is stated that it is the signal converter that
converts the electrical signals to optical signals, which allows
the transmission to be free from interference.

     The RFC504 Printer Cable as a whole, however, is designed to
connect computers and printers for the purpose of conducting
                               -3-

signals between computers and printers.  The fiber optic cable
fitted with connectors is the component which connects the
computers and printers and acts as the conducting medium.  The
signal converters assist in this regard by preparing the signals
for transmission, but the conversion of signals is only performed
for the purpose of transmitting signals through the cables.  The
signal converters at the printer end of the cable merely transfer
the signals back to electrical signals, the same form the signals
were in as they were output by the computer prior to being
transmitted through the cables.

     The importer states that the cables and connectors would
only make up approximately 29% of the cost of the product, with
the cost of the signal converters making up the balance.  The
cost of the components, however, is not the determining factor in
finding the essential character of this particular product.  This
printer cable is strictly a functional product.  The nature of
the components and their role in performing the intended function
of the product are especially pertinent in this regard.  The
fiber optic cables fitted with connectors, not the signal
converters, are the components which connect computers and
printers and conduct signals between computers and printers.  The
fiber optic cable fitted with connectors is the component which
gives the RFC504 Printer Cable its essential character.

     The importer argues that the product is classified in
Heading 8471 as machines for transcribing data onto data media
in coded form.  Assuming, arguendo, that the signal converters
are described by Heading 8471, the RFC504 cable would still not
be classified in Heading 8471.   Because the essential character
of the product is imparted by the cable fitted with connectors,
the product is classified as fiber optic cable, not as signal
converters.

     The RFC504 Fiber Optic Printer Cable is classified as
optical fiber cables, made up of individually sheathed fibers,
fitted with connectors, in 8544.70.00, HTSUSA.

HOLDING:

     The RFC504 Fiber Optic Printer Cable is classified as
optical fiber cables, made up of individually sheathed fibers,
fitted with connectors, in 8544.70.00, HTSUSA.

                              Sincerely,





                              John Durant, Director
                              Commercial Rulings Division