CLA-2-84:RR:NC:1:103 E86026
Mr. Saul L. Sherman
Attorney at Law
P.O. Box 820
Water Mill, NY 11976-0820
RE: The tariff classification of cutting and handling machinery from Germany
Dear Mr. Sherman:
In your letter dated Aug. 2, 1999 on behalf of Armstrong World Industries, Inc. you requested a tariff classification ruling.
Your client intends to import, in four separate shipments, a line of machinery for cutting, winding and packaging vinyl flooring. You submitted a detailed engineering drawing of the complete line, color coded to indicate the components which will be imported in each of the four shipments. The line will be used to convert large rolls of vinyl flooring, measuring over 12 feet in width, over 6 feet in diameter, and weighing up to 12,800 pounds, into smaller rolls. These smaller rolls, which will be either 6 feet or 12 feet in width and weigh from 200 to 1000 pounds, will then be shipped to flooring distributors for retail sale. The complete line will consist of various machines which will unwind the large parent rolls, slit the flooring lengthwise (when the 6 foot width is required), cut the flooring to length, and rewind the cut material onto paperboard cores. Additional machinery will then wrap and label the resulting smaller rolls, and place end caps into the ends of the roll cores. The line will also include equipment for aligning the flooring and trimming its edges, maintaining proper tension on the material as it passes through the various machines, storing it temporarily on accumulator conveyors, detecting and removing or replacing defects in the flooring, and delivering the wrapped rolls to a loading dock.
The initial shipment will consist of the following specific articles (the Armstrong equipment number is shown in parenthesis):
1. A machine for cutting and splicing the vinyl flooring (6);
2. Various pull sections and dancer rollers to move the flooring material through the line (7, 13, 14, 17, 18);
3. A machine for trimming the edges of the flooring (10);
4. A roller table which allows a worker to visually inspect the material for defects (11, 11a, 12);
5. Accumulator conveyors to ensure a steady flow of material (15, 16, 19, 20).
The applicable subheading for the cutting and splicing machine, and for the edge trimming machine, will be 8477.80.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for machinery for working rubber or plastics or for the manufacture of products from these materials, not specified or included elsewhere (in chapter 84): other machinery. The rate of duty will be 3.1 percent ad valorem.
The applicable subheading for the roller table and accumulator conveyors will be 8428.39.0000, HTS, which provides for other lifting, handling, loading or unloading machinery: other continuous-action elevators and conveyors, for goods or materials: other. The duty rate will be free.
The applicable subheading for the various pull sections, together with their dancer rollers, will be 8428.90.0090, HTS, which provides for other lifting, handling, loading or unloading machinery: other machinery: other: other. The duty rate will again be free.
Your inquiry does not provide enough information for us to give a classification ruling on the pivot guide stand (9) and the edge guide platform (21b). Your request for a classification ruling should include a description of these articles, as well as a statement indicating what function they perform. When this information is available, you may wish to consider resubmission of your request. We are returning any related samples, exhibits, etc., but are retaining the engineering drawing for use with future ruling requests which we understand you will be submitting. If you decide to resubmit your request, please include all of the material that we have returned to you.
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 Alan Horowitz at 212-637-7027.
Sincerely,
Robert B. Swierupski
Director,
National Commodity
Specialist Division