CLA-2-84:S:N:N1:105 885949

Mr. Terrence L. Mc Cracken
R.J. Mc Cracken CHB
5345 44th Street, S.E.
Grand Rapids, MI 49512-4001

RE: The tariff classification of heat equipment from Switzerland

Dear Mr. Mc Cracken:

In your letter dated May 3, 1993 you requested a tariff classification ruling on behalf of Hill Machinery Company. You submitted brochures on the following: the Leister Modular Temperature Controller, Leister hot air welding tools, the Leister- Forte "S3" hot air blower for pallet hood shrinking, and the Leister hot air blowers for shrinking, welding, drying, activating, sterilizing, heating lighting fuel, and soldering.

The Modular Temperature Controller is a digital temperature controller with built-in voltage regulator and thermal probe. The unit regulates voltage to a heat gun in order to control the gun's heat output.

The hot air welding tools are: the Leister Hand Welding Tool "Triac", for repair welding of thermoplastic inflatable boats and lorry covers, and for continuous mesh welding of 0.2 mm thick polyethylene sheet; the Leister Hot Air Automatic Welding Machine "Universal", suitable for overlap welding of thermoplastic foils of 0.5 to 3mm thickness at a speed of 3 to 4 meters per minute, and the Leister Automatic Hot Air Welding Machine "Variant", also suitable for overlap welding, but at speeds of 8 to 10 meters per minute. The Triac's welding temperature is infinitely variable between 20 and 700 degrees C, while the Universal's and Variant's range is 20 to 650 C.

The Forte "S3" is designed for the hot air shrinking of plastic wrap hoods. Proper wrapping is achieved by moving the hot air gun at right angles to the pallet with the nozzle as close as possible to the hood, while moving it along at a speed of 0.3 meter per second.

The other hot air blowers are the Hotwind "S" and the Vulcan "S". The Hotwind's airflow (300 to 600 liters per minute) is lower than that of the Forte "S3" (1,000 l/m), while the Vulcan "S"'s is higher (900-1400 l/m). The Hotwind's air temperature is infinitely variable up to 800 C., the Vulcan's to 680 C, whereas the Forte "S3"'s operating temperature is 600 C.

The applicable subheading for the Modular Temperature Controller will be 9032.89.6040, Harmonized Tariff Schedule of the United States (HTS), which provides for automatic regulating or controlling instruments and apparatus: other: other. The duty rate will be 4.9 percent ad valorem. The applicable subheading for the Triac, Universal and the Variant will be 8515.80.0080, HTS, which provides for electric (including electrically heated gas) welding machines and apparatus, whether or not capable of cutting; other. The duty rate will be 2 percent ad valorem.

The question of classification for the Forte "S3", Hotwind "S", and Vulcan "S" is being referred to the Office of Regulations and Rulings, U.S. Customs Service Headquarters, 1301 Constitution Avenue, N.W., Washington D.C. 20229. A ruling will be issued to you from that office.

This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177).

A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction.

Sincerely,

Jean F. Maguire
Area Director
New York Seaport