CLA-2-84:RR:NC:1:103 E87164

Mr. Saul L. Sherman
Attorney at Law
PO Box 820
Water Mill, NY 11976-0820

RE: The tariff classification of core and scrap conveying systems from Germany

Dear Mr. Sherman:

In your letter dated September 7, 1999 on behalf of Armstrong World Industries, Inc. you requested a tariff classification ruling.

Your client intends to import, in four separate shipments, a line of machinery for cutting, winding and packaging vinyl flooring. You submitted a detailed engineering drawing of the complete line, color coded to indicate the components which will be imported in each of the four shipments. The line will be used to convert large rolls of vinyl flooring, measuring over 12 feet in width, over 6 feet in diameter, and weighing up to 12,800 pounds, into smaller rolls. These smaller rolls, which will be either 6 feet or 12 feet in width and weigh from 200 to 1000 pounds, will then be shipped to flooring distributors for retail sale. The complete line will consist of various machines which will unwind the large parent rolls, slit the flooring lengthwise (when the 6 foot width is required), cut the flooring to length, and rewind the cut material onto paperboard cores. Additional imported machinery will then wrap and label the resulting smaller rolls, and place end caps into the ends of the roll cores. The line will also include equipment for aligning the flooring and trimming its edges, maintaining proper tension on the material as it passes through the various machines, storing it temporarily on accumulator conveyors, detecting and removing or replacing defects in the flooring, and delivering the wrapped rolls to a loading dock.

In Ruling Letter E86026 dated Aug. 31, 1999 we provided you with the tariff classification of various articles which comprised the initial importation of this machinery line. Your current letter provided information on the second shipment, which will contain the following specific articles (the Armstrong equipment number is shown in parenthesis):

1. A core conveying system, composed of 6 foot and 12 foot core dispensers (26, 27), 6 foot and 12 foot core elevator infeeds (26a, 27a), 6 foot and 12 foot core elevators (28, 29), and a core delivery unit (30), all of which are used to transport paperboard cores from a storage area to roll winding machinery.

2. A scrap conveying system, composed of 2 scrap conveyors (41, 42), 6 foot and 12 foot scrap roller tables (43, 45), and a 6 foot scrap dump board (44), all of which are used to transport scrap flooring material away from the line for separate disposition.

The applicable subheading for the core conveying system and the scrap conveying system, each of which is a functional unit imported in a single shipment, will be 8428.39.0000, HTS, which provides for other lifting, handling, loading or unloading machinery: other continuous-action elevators and conveyors, for goods or materials: other. 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 Alan Horowitz at 212-637-7027.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division