CLA-2-84:RR:NC:1:103 F82506
Mr. Saul L. Sherman
Attorney at Law
PO Box 820
Water Mill, NY 11976-0820
RE: The tariff classification of unwinding, handling and slitting machinery from Germany
Dear Mr. Sherman:
In your letter dated January 25, 2000 on behalf of Armstrong World Industries, Inc. you requested a tariff classification ruling.
Your client intends to import, in multiple 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 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 Letters NY E86026 dated Aug. 31, 1999 and NY E87164 dated Sept. 28, 1999 we provided you with the tariff classification of various articles which comprised the first and second importations of this machinery line. Your current letter provided information on the third shipment, referred to as shipment 2a by your client, which will contain the following specific articles (the Armstrong equipment number is shown in parenthesis):
1. An unwinding group used to unwind the parent rolls of flooring, consisting of two unwinders (1, 3), each with its own guider (2, 4), connected by a short conveyor (5).
2. A dancer unit (8), an edge guider unit (21a), and a swing dancer (22a) which assist in tensioning and moving the flooring material through the line.
3. A slitting machine (23) used to slit the flooring.
4. An operator platform (32) comprised of a catwalk and supporting uprights of steel and aluminum.
5. A programmable logic controller (69) used to operate a drive mechanism (68) to which it is connected by a cable.
The applicable subheading for the unwinding group, which is a composite machine having a single manufacturer’s identification number, will be 8479.89.9797, Harmonized Tariff Schedule of the United States (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 rate of duty will be 2.5 percent ad valorem.
The applicable subheading for the dancers and edge guider will be 8428.90.0090, HTS, which provides for other lifting, handling, loading or unloading machinery: other machinery: other: other. The rate of duty will be free.
The applicable subheading for the slitting machine will be 8477.80.0000, HTS, which provides for machinery for working rubber or plastics or for the manufacture of products from these materials, not specified or included elsewhere (in Chapter 84): other machinery. The rate of duty will be 3.1 percent ad valorem.
The applicable subheading for the operator platform will be 7308.90.9590, HTS, which provides for structures and parts of structures of iron or steel: other: other: other: other: other. The rate of duty will be 2.3 percent ad valorem.
Finally, the applicable subheading for the programmable logic controller together with the drives, which again have a single manufacturer identification number, will be 8537.10.9060, HTS, which provides for boards, 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….for a voltage not exceeding 1000 V: other: programmable controllers. The rate of duty will be 2.7 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 212-637-7027.
Sincerely,
Robert B. Swierupski
Director,
National Commodity
Specialist Division