CLA-2-84:RR:NC:1:104 E86595
Ms. Sheri G. Lawson
PBB Global Logistics
434 Delaware Avenue
Buffalo, NY 14202
RE: The tariff classification of molds for concrete from Austria
Dear Ms. Lawson:
In your letter dated September 13, 1999 on behalf of Sherman-Dixie Concrete of Franklin, Tennessee you requested a tariff classification ruling.
The equipment consists of external molds, pallets, table plates and master headers for forming concrete pipe on a two position pipe molding machine (one position for making the finished product and one for removing the finished pipe). The steel external molds used to form the outside of concrete pipe splits ¼” at one seam to allow the pipe to be released and has a latching mechanism attached to the outside which automatically opens and closes. Each mold has from three to eight steel pallet locks on it, depending on the size of the mold, which hold the pallet (the mold base) in place during the manufacturing process. Each mold also has two pneumatic cage centering units, one at the top and one at the bottom. These are steel plates that go through a slot in the mold frame and extend a predetermined distance into the mold to properly position the wire reinforcements in the concrete pipe during the molding process.
A cast steel pallet is locked onto the bottom of each mold, using the pallet locks, to form the bell-shaped bottom (female end) of the pipe. The pallet is necessary to complete the mold. When the pipe is removed from the mold, it is not finished drying so the pipe is kept on the pallet until the pipe is dry. Another pallet must be ready to clamp to the mold to keep production going. For this reason, many extra pallets will be imported for each size mold.
The table plates are steel alignment guides that will be mounted onto the molding machine to indicate where the molds are to be placed. They are not a part of the mold.
Each mold size (not each mold) requires a masterheader which is mounted on the molding machine. The master header forms the spigot or head of the pipe. The spigot (also called the tongue or male end) of the pipe is smaller than the main part so it can fit together with the bell-shaped female end. During the production process, the mold rotates underneath the steel masterheader which is lowered into the mold about 2”. Production starts as the concrete is packed into the mold and pressed against the masterheader to form the spigot. The masterheader is raised out of the mold after the pipe has been formed.
The inside of the pipe is formed by a roller head (aka packer head). It is a hollow cast steel cylinder with round steel rollers on it. If the size of pipe to be molded is changed, the roller head on the machine must be changed accordingly. The head is lowered into the external mold on a shaft attached to the top table of the machine. The shaft goes through the top of the roller head down to the pallet. The head rotates rapidly packing the very dry concrete mix against the side of the mold as it climbs out of the mold. The roller head is not imported. It’s made in the U.S.
The current contract calls for nine different mold sizes. You have provided documentation that indicates that complete sets for each size will be imported. (For example, one of the shipments will include complete sets of 12” and 30” molds.) A complete set includes 2 molds, 1 masterheader, 2 table plates and from 81 to 300 bottom pallets, the quantity varying with more extra pallets for the smaller molds than the larger. A single complete mold includes an external mold, 1 pallet and 1 masterheader.
The applicable subheading for the molds (1 external mold with 1 pallet, with or without 1 masterheader) will be 8480.60.0010, Harmonized Tariff Schedule of the United States (HTS), which provides for molds for mineral materials. The rate of duty will be free.
The extra pallets will be classified under HTS subheading 8480.20.0000 which provides for mold bases. The rate of duty will be 3.4 percent.
The applicable subheading for the table plates will be 8474.90.0090, HTS, which provides for parts of machinery for agglomerating, shaping or molding … other mineral products in powder or paste form. The rate of duty will be free.
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 Robert Losche at 212-637-7038.
Sincerely,
Robert B. Swierupski
Director,
National Commodity
Specialist Division