CLA-2-84:S:N:N1:103 850665

Mr. Scott A. Cohn
Grunfeld, Desiderio, Lebowitz & Silverman
12 East 49th Street
New York, N.Y. 10017

RE: The tariff classification of a coating machine and die coating head from Japan

Dear Mr. Cohn:

In your letter dated March 15, 1990 on behalf of Kao Infosystems Company you requested a tariff classification ruling.

The coating machine, product number K-200, applies a solvent-based magnetic coating onto a continuous plastic sheet which is fed through the machine. It incorporates a multi-zone dryer which removes the solvent, thus leaving a thin film of magnetic particles on the plastic sheet, as well as unwinding and rewinding stations for the rolls of continuous plastic material. The electrical operator control panels will be imported together with the coater. We understand that this coater does not function by means of a spraying action. A small laboratory version of the coater, product number ZL-883, used for testing purposes, will also be imported. The K-201 die coating head, imported separately, will be used as an alternative coating head in the coating machine. It hydraulically spreads the magnetic coating onto the plastic substrate.

The applicable subheading for the K-200 coating machine, imported together with its control panels, and for the ZL-883 laboratory coater will be 8479.89.9090, Harmonized Tariff Schedule of the United States (HTS), which provides for other machines and mechanical appliances having individual functions, not specified or included elsewhere in this chapter. The rate of duty will be 3.7 percent ad valorem.

The applicable subheading for the K-201 die coating head will be 8479.90.8090, HTS, which provides for other parts of machines and mechanical appliances having individual functions, not specified or included elsewhere in this chapter. The rate of duty will also be 3.7 percent ad valorem. Importation of these items will not require a visa, nor are they subject to any voluntary restraint agreement.

Your inquiry does not provide enough information for us to give a classification ruling on the ZL-200 coating thickness meter. Your request for a classification ruling on this item should include the following: 1. Descriptive brochure, if available; 2. An explanation as to how the instrument performs its measurements; 3. A statement as to whether optical elements are contained in the instrument and, if so, what they are; 4. A statement as to the light source used by the instrument, and whether the instrument contains a laser.

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