CLA-2-84:RR:NC:1:103 D83615
Ms. Marcela Szerena
Circle International
540 Rockaway Avenue,
Valley Stream, NY 11581
RE: The tariff classification of a downcoiler and hydraulic
accumulators from Japan
Dear Ms. Szerena:
In your letter dated October 9, 1998 on behalf of IHI Inc. you
requested a tariff classification ruling.
Your client intends to import a downcoiler system for use in
a hot strip mill. Literature submitted with your inquiry indicates
the AJC hydraulically controlled downcoiler is intended to coil
strip steel onto a mandrel by means of wrapper rollers. The unit
incorporates an automatic jumping control which utilizes electronic
sensors, along with a hydraulic roll position control system, to
ensure the wrapper rolls are firmly pressed against the strip as it
is wound. This prevents gaps, loose coils and slip marks from
forming as the wound material passes over the strip's beginning
edge.
Your letter states that the downcoiler and its associated
equipment will be imported in several shipments occurring over a
period of 6 to 8 months. However, a shipping schedule included
with your submission lists four separate shipments, with the
initial shipment apparently consisting of an accumulator stand for
the unit's hydraulic system. This schedule also indicates that two
shipments will be composed solely of unspecified parts.
The downcoiler does not form metal, but simply takes metal
strip which has already been formed and winds it around a roll.
Thus classification of the downcoiler in subheading 8462.29.8055,
Harmonized Tariff Schedule of the United States (HTS), which
provides for other bending, folding, straightening, or flattening
machines (including presses), as mentioned in your letter, is not
appropriate.
Assuming the AJC hydraulic downcoiler itself is imported in a
single shipment, the applicable subheading will be 8479.89.9797,
HTS, which provides for machines and mechanical appliances having
individual functions, not specified or included elsewhere (in
chapter 84): other machines and mechanical appliances: other:
other: other: other. The duty rate will be 2.7 percent ad valorem.
The applicable subheading for hydraulic accumulators, shipped
separately, will be 8479.89.9765, HTS, which provides for machines
and mechanical appliances having individual functions, not
specified or included elsewhere (in chapter 84): other machines and
mechanical appliances: other: other: other: hydraulic accumulators.
The rate of duty will again be 2.7 percent ad valorem.
Your inquiry does not provide enough information for us to
give a classification ruling on the downcoiler parts or other
associated equipment. In general downcoiler parts, not excluded by
virtue of note 1 to section XVI or note 1 to chapter 84, and not
provided for as goods included in any of the headings of chapter 84
and chapter 85 in accordance with note 2(a) to section XVI, and
which are solely or principally used as parts of a downcoiler would
be classifiable in subheading 8479.90.9785, HTS, which provides for
parts of machines and mechanical appliances having individual
functions, not specified or included elsewhere (in chapter 84):
other: other: other. The rate of duty currently associated with
subheading 8479.90.9785 is 0.7 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