NY 859751
Feb. 11, 1991
CLA-2-84:S:N:N1:103 859751
8428.33.0000
Mr. Scott A. Cohn
Grunfeld, Desiderio, Lebowitz & Silverman
12 East 49th Street
New York, N.Y. 10017
RE: The tariff classification of armature and stator
manufacturing machines from Italy
Dear Mr. Cohn:
In your letter dated January 21, 1991 on behalf of Axis USA,
Inc. you requested a tariff classification ruling.
This request represents one of several ruling requests you
have submitted covering the importation of various machines for
the manufacture of armatures and stators. The armatures and
stators made by this equipment will be used as components of
electric motors for small household appliances, power tools, and
automobile DC motors.
Armatures basically consist of coils of wire wound around an
iron core. They are produced by assembling metal laminations, or
stacks, into a cylindrical shape and then inserting a shaft into
slots in the stacks. A commutator, consisting of a molded
plastic ring surrounded by a copper shell, is then placed onto
the end of the shaft, and wires are wound around the shaft and
fused to the commutator. During this process insulating
materials are inserted at various stages so as to protect the
armature components and wires, and the wires are coated with a
resin to protect them from dirt and wear. Finally, the
electrical connections in each completed armature are tested.
The armatures are transported on metal pallets along a conveyor
system from machine to machine as the assembly process occurs.
Stators, which are stationary parts of a motor about which a
rotor revolves, are produced in much the same fashion.
You inquired about the following specific machines:
1. Models DAW or MAW automatic armature winders - these
machines utilize winding arms to wind an insulated copper wire
around the armature shaft on the inside of the stack slots and
hook the wire to tangs located on the commutator ring at the end
of the armature shaft.
2. Model ETD electronic wire tensioner - an electronic
device which may be fitted to an armature winding machine to
control the tension of the copper wire during the winding
process. Wire tension is regulated by means of an angular
position indicator and an electromagnetic brake.
3. Model WIM armature wedge inserting machine - a machine
used to mechanically insert a protective paper wedge over the
exposed portion of the insulated copper wire which has been wound
around an armature shaft.
4. Model FPM fan placing machine - a machine used to press
a fan blade onto the end of the armature shaft in order to cool
the motor in which the armature will be used.
5. Conveyor systems and pallets - belt conveyors used to
move a specific number of individual pallets, each holding an
armature or stator, from machine to machine. The metal pallets,
which are specially tooled to accommodate a particular armature
or stator, will be imported with the conveyor. The pallets are
lifted from the conveyor onto several of the armature and stator
assembly machines for the purpose of processing the armatures and
stators carried on the pallets. Also, the pallets contain
mechanical or magnetic memory devices which enable status data to
be encoded and retrieved by the assembly machines.
Control panels for each machine described above may also be
imported with the particular machine.
The applicable subheading for the Model DAW and Model MAW
automatic armature winders, and the Model WIM armature wedge
inserting machine, will be 8479.81.0000, Harmonized Tariff
Schedule of the United States (HTS), which provides for other
machines and mechanical appliances for treating metal, including
electric wire coil-winders. The rate of duty will be 3.7 percent
ad valorem.
The applicable subheading for the Model ETD electronic wire
tensioner will be 8537.10.0070, HTS, which provides for other
boards, panels (including numerical control panels), consoles,
desks, cabinets and other bases, equipped with two or more
apparatus of heading 8535 or 8536, for electric control or the
distribution of electricity, including those incorporating
instruments or apparatus of chapter 90, other than switching
apparatus of heading 8517, for a voltage not exceeding 1000
volts: other. The rate of duty will be 5.3 percent ad valorem.
The applicable subheading for the Model FPM fan placing
machine will be 8479.89.9090, HTS, which provides for other
machines and mechanical appliances having individual functions,
not specified or included elsewhere: other. The rate of duty
will be 3.7 percent ad valorem.
Finally, the applicable subheading for the functional unit
formed by the conveyor system and its special pallets will be
8428.33.0000, HTS, which provides for other belt type continuous-
action conveyors, for goods or materials. The rate of duty will
be 2 percent ad valorem.
A control panel imported together with the machine it will
control will be classified in the same subheading as the machine.
The above merchandise is not subject to any Voluntary Restraint
Agreements or visa requirements.
In a supplemental letter dated January 31, 1991 you also
inquired about disassembled machines and parts. In the absence
of specific information, we are unable to provide you with a
ruling on these matters. However, for your information, a
particular heading for a machine includes such a machine in a
disassembled state, per General Rule of Interpretation 2(a). If
the importation does not contain all the components of the
disassembled machine, it will still be classified in the heading
for the complete machine provided it has the essential character
of the complete machine. Parts of machines, including spare
parts, which are not goods provided for in any of the other
headings of chapters 84 or 85, nor excluded from chapters 84 or
85, will be classified in the same heading as the machine of
which they are a part provided they are solely or principally
used with such machine (see Notes 1 and 2 of section XVI, Note 1
of chapter 84, and Note 1 of chapter 85, HTS).
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