CLA-2-84:RR:NC:1:103 D82211

Ms. Jennifer F. Kessinger
Katten Muchin & Zavis
525 West Monroe Street, Suite 1600
Chicago, IL 60661-3693

RE: The tariff classification of injection molding machine components from Germany

Dear Ms. Kessinger:

In your letters dated July 28, 1998 and September 10, 1998 on behalf of Cincinnati Milacron, Inc. (CMI) you requested a tariff classification ruling.

You submitted a schematic drawing and samples of a screw tip, distance ring, and seat (or non-return ring) which will be separately imported in various sizes by your client. These items will then be combined together to form a screw tip assembly used in a plastic injection molding machine. Because of their unique design, each screw tip assembly will be used in a particular line of injection molding machines manufactured by CMI and cannot be used in any other line of injection molding machines, or in any other type of machine.

Plastic injection molding machines utilize a barrel screw which rotates within a heated barrel to inject molten plastic into a mold. The screw tip assembly is positioned at the front of the barrel screw. As the screw rotates the distance ring moves forward, allowing the aperture between the barrel and distance ring to open. The molten plastic can then pass through the screw tip and accumulate in front of the screw. The accumulation of melted plastic in front of the screw forces the screw toward the rear. Once the desired amount of plastic has been accumulated the screw is shot forward, thus injecting the plastic into the mold. The distance ring moves backward during injection, closing the aperture and preventing material from flowing back along the screw during injection. The seat (or non-return ring) functions as a stop for the distance ring. The seat is not incorporated in the screw tip since it is subject to substantial wear and thus is replaced more often than the screw tip.

While it acts to regulate the flow of the molten plastic within the injection molding machine, the screw tip assembly seals against the barrel and thus does not form a complete valve. Accordingly, the components of the screw tip assembly cannot be classified in heading 8481, Harmonized Tariff Schedule of the United States (HTS), which provides for, among other things, valves and parts thereof.

The applicable subheading for the screw tip, distance ring and seat (non-return ring), imported individually, will be 8477.90.8515, HTS, which provides for parts of machinery for working rubber or plastics or for the manufacture of products from these materials, not specified or included elsewhere (in chapter 84): other: other: of injection molding machines. The rate of duty will be 3.3 percent ad valorem.

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 212-466-5494.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division