CLA-2-84:RR:NC:1:104 F84651
Mr. Thomas J. O’Donnell
Rodriguez O’Donnell
Fuerst Gonzalez & Williams
20 North Wacker Drive, Suite 1416
Chicago, Illinois 60606
RE: The tariff classification of press frames, a universal mounting table and a power tool accessory from Germany.
Dear Mr. O’Donnell:
In your letter dated March 16, 2000 on behalf of TOX-Pressotechnik, L.L.C. of Warrenville, Illinois you requested a tariff classification ruling.
The cast steel press frames are parts of compact presses typically used in metal forming operations to straighten, punch, stamp, bend, rivet, draw, or mark metal. The type CEC press frame is part of a floor mounted C-frame hydraulic press. The type MCC frame is part of a bench mounted C-frame hydraulic press.
The steel universal mounting table is an accessory item that provides a mounting fixture for TOX’s C-frame and 2 and 4 column hydraulic presses. The table has ergonomic cutouts for the mounting of control valves. The table top is either predrilled at the TOX factory to mount the available presses or is drilled by the importer to customer specifications. The table has knockout holes in its sides and built in mounting brackets that allow for mounting of various electrical and hydraulic controls. The table is predrilled at the factory for the mounting of a protective guard that surrounds the table top.
The CZS steel gimbal with hangar is an accessory item for the TOX CMH mini-portable hydraulic gun, a tool used for operations such as riveting, crimping, etc. It is made to fit the cylinder barrel of a CMH gun and mounts the gun to a type KT TOX Power Package (a combination pneumatic/hydraulic engine). This allows the gun operator to operate the gun with one hand and to hold the workpiece with the other. It relieves the operator from having to hold the gun while operating it yet allows some movement in positioning the gun because of the swivel gimbal. It is not designed to merely hold the mini-gun while not in use, i.e., as a tool rest.
You have suggested that the press frames and the universal mounting table are classifiable under HTS subheading 8466.94.6585 as parts of machine tools and that the steel gimbal with hangar falls under 8467.99.0090 as parts of tools for working in the hand, pneumatic, hydraulic or with self-contained non-electric motor. You have described the universal mounting table and the steel gimbal with hangar in your letter as “accessory items”. The brochure for the table lists it as an “option” for the press and the brochure for the mini-portable gun refers to the gimbal with hangar as accessories. We agree that these items are accessories. The classifications you have suggested do not include accessories.
The applicable subheading for the type CEC and MCC cast steel press frames will be 8466.94.6585, Harmonized Tariff Schedule of the United States (HTS), which provides for parts for machines of heading 8462 or 8463: other: bed, base, column, cradle, frame, bolster, crown, slide, rod, tailstock, and headstock castings, weldments or fabrications: other. The rate of duty will be 4.7 percent.
The applicable subheading for the universal mounting table will be 8466.30.8000, HTS, which provides for other special attachments for machine tools: other: other. The rate of duty will be 8 percent.
The applicable subheading for the steel gimbal hangar will be 7326.90.8585, HTS, which provides for other articles of iron or steel: other: other: other. The rate of duty will be 2.9 percent.
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