CLA-2-84:OT:RR:NC:1:104
Mr. David Peterson
Perfect Point EDM Inc.
15000 C Bolsa Chica St.
Huntington Beach, CA 92649
RE: The tariff classification of the e-drill™ system
Dear Mr. Peterson:
In your letter dated July 20, 2012, you requested a tariff classification ruling.
The Perfect Point™ e-drill™ system is designed to use the electro discharge machining (“EDM”) to remove rivets from aircraft. The hand held e-drill™ replaces the traditional method of using a twist drill to remove the rivets. The device contains a self-contained DC stepper motor. Located inside of the hand tool housing, this motor is part of the mechanism that automatically positions the electrode during the cutting process. The motor is actuated by pressing on the hand tool’s trigger button. This action starts the cutting process.
The EDM process weakens the fasteners by electrically eroding a circular groove through the fastener head and a short distance into the stem (or pin) of the aircraft fastener. The depth of cutting is controlled automatically. A thin wall is formed holding the fastener head in place. The fastener head may then be easily severed by a sharp tap of a hammer and a hand punch. Due to the depth of the cut, the fastener stem leaves no remnant burr which may enlarge the hole in the airframe as the stem is driven out.
The e-drill™ system is comprised of the e-drill™ hand-tool with its umbilical cable assembly, an operator electronic control terminal and cable assembly, electrical power supply cabinet assembly and an umbilical cable extension assembly. Various special adaptors and electrodes are included for removal of specific fastener configurations and materials. The e-drill™ itself measures 7.5” x 5” x 2”, weighs 1.5 lbs and includes 10 ft. of umbilical. The maximum duty cycle is 30 fasteners or as many as possible with one electrode (whichever is the least) at the rate of 3 fasteners/minute (totaling 10 minutes) with a 1 minute minimum recovery time.
The applicable subheading for the Perfect Point™ e-drill™ system as described above will be 8467.21.0070, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Tools for working in the hand, pneumatic, hydraulic or with self-contained electric or non electric motor, and parts thereof: With self-contained electric motor: Drills of all kinds: Other, including hammer drills.
In your letter, you also request a classification ruling on subassemblies for the system that may be shipped individually. Your inquiry does not provide enough information for us to give a classification ruling on these subassemblies or parts. Your request for a classification ruling should include a list of these subassemblies by name, description, function/use and method of operation. Please be advised that “parts” are classified in accordance with Note 2 to Section XVI, HTSUS.
When this information is available, you may wish to consider resubmission of your request. Please limit your ruling request on the subassemblies to a maximum of 5 items of the same class or kind.
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 Patricia O’Donnell at (646) 733-3011.
Sincerely,
Thomas J. Russo
Director
National Commodity Specialist Division