Telecommunication parts classification: populated circuit boards integral to switch equipment were treated as parts, not independent machines.

Populated printed circuit cards used in Photonic Service Switch equipment were classified as parts under Heading 8517 70 10, not as independent telecommunication machines under Heading 8517 62 70. The technical literature showed that the cards were inserted into and operated only as components of the main switch, while the Department produced no technical material, sampling, or expert evidence to establish independent functionality. The HSN notes were read as applying to complete apparatus, and the decisive principle applied was that an item which cannot function independently and is integral to the working of the main equipment is classifiable as a part rather than as a standalone machine.

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Issues: Whether the imported cards, being populated printed circuit boards used in Photonic Service Switch equipment, were classifiable as machines for reception, conversion and transmission or regeneration of voice, images or other data under Heading 8517 62 70, or as parts under Heading 8517 70 10.

Analysis: The relevant tariff structure places the goods in Heading 8517 under distinct categories for telecommunication apparatus and for parts. The goods were supported by technical literature showing that they were inserted into and operated as components of the Photonic Service Switch, and the Department produced no technical material, sampling, or expert evidence to show independent functionality. The HSN notes relied on by the Department were read as referring to complete apparatus, while the imported items were found to be populated circuit boards forming integral parts of the main equipment. The reasoning also followed the principle that a device which cannot function independently and is integral to the operation of the main equipment is to be classified as a part and not as a standalone machine.

Conclusion: The cards were classifiable under Heading 8517 70 10 as parts, and not under Heading 8517 62 70 as independent machines.

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