CLA-2-84:OT:RR:NC:1:104
8477.30.0000; 8479.82.0040
Ms. Luanne M. Ciaccio
Pride International Inc.
2200 Broening Highway
Suite 230
Baltimore, MD 21224
RE: The tariff classification of an Automatic Vodka Filling Line from China
Dear Ms. Ciaccio:
In your letter dated December 20, 2013, on behalf of your client, Petrus USA LLC, you requested a tariff classification ruling.
You are seeking the tariff classification of various machines that comprise a vodka filling production line. You have requested a ruling as to the tariff classification of these goods under the following two scenarios: (a) the entire production line is imported complete in one shipment and (b) each machine is imported separately. The machines in question are as follows:
A semi-automatic bottle blowing machine which is suitable for blowing PET bottles with different shapes and a volume from 100ml to 5000ml. The machine is controlled by a PLC, Microsoft-computer touch screen and the preform is heated by infrared ray constant pressure control. It contains a voltage of 220-380V, 3n 50-60Hz and a heating power of 16KW.
The LH-54 automatic rotary bottle washing machine which contains 54 heads, a dimension of 3000x750x1500mm and a power of 0.37kw. The production capacity is 500-3500b/h.
The LH-12 vodka automatic filling machine, which is a compact structure that is easy to operate, has low power consumption with complete functions. The model is an inline type filling machine with Mitsubishi programmable control, Omron photoelectric sensor, and pneumatic enforcement is the integration of high-tech filling equipment. The machine is suitable for jam, seasoning, wine, mineral water and other liquid filling. The electrical source is 220V with 12 filling heads and a production capacity of 3000-6000 bottles/hour (500ML). The machine’s weight is about 300kg.
The light inspector contains a stainless steel outside cover and provides a soft, comfortable ray of light. The light inspector complies with the national hygiene standards and inspects for impurities and particulate matter.
The XG-1 automatic cap screwing machine is used for capping and screwing the PET bottle and plastic bottles. It is used for caps with different materials and different specifications. It applies various caps such as the spiral cap, protective cap and the press-in cap. The machine contains a torque screwing head to adjust the pressure conveniently. The power unit is 0.75kw, bottle height of 150-320mm, bottle diameter of 50-100mm and a production capacity of 1000-2800BPH. The machine size is shown as 940*700*2000mm.
The two-side bottle labeling machine has a speed of 35M/Minute, labeling precision of ±1mm and a label width of 200mm max. The dimension of the machine is 3048x1700x1500mm.
The automatic date printing machine prints 1-3 lines using alphabet and numbers, prints with black ink and is able to print various materials such as jet printing of metal, plastic, glass wood, and pipeline construction materials. It features a 1.5mm stainless steel sealed chassis, a printing speed of 1400 characters (5x7) and a printing distance using a nozzle max distance of 30mm. The machine also contains a fully enclosed ink cycling system.
The semi-automatic bottle wrapping machine contains a voltage of 220V 50/60HZ, a packing speed of 2-5 pcs/minute, a film width of 500mm/0.04-0.1 max and a thickness of 2mm. The machine uses shrinking film of PE, POF, PVC, and PP.
The conveyor belt, which connects items 2 through 7, inclusive, is a standard stainless steel belt
(10) The speed control power unit contains a variable transmission and a motor speed control.
You are also requesting a tariff classification on plastic material that will be used to blow the bottles. This includes plastic caps for the bottles and bottle preforms that will be inserted into a mold and then installed into the blowing machine. The finished product will be the bottle. It contains a volume of 500-2500ML, a capacity of 500 BPH, diameter of 70-150mm and a bottle neck diameter of 32mm. The material used is PET.
Another item separately imported are 6 mixing tanks of 5000 liters each with a material of SS304 (Stainless Steel), and dimensions of 1700mm X 2000mm x 4mm. The tanks also contain an agitator of 4KW, 72rpm (440V, 60HZ, 3 phase). The tanks contain a breather orifice and other orifices and an inlet and output orifice of DN32.
When imported separately, the following subheadings will apply:
The applicable subheading for the plastic bottle preforms will be 3923.30.0090, HTSUS, which provides for Articles for the conveyance or packing of goods, of plastics; stoppers, lids, caps and other closures, of plastics: Carboys, bottles, flasks and similar articles: Other. The rate of duty will be 3 percent ad valorem.
The applicable subheading for the plastic caps will be 3923.50.0000, HTSUS, which provides for Stoppers, lids, caps and other closures. The rate of duty will be 5.3 percent ad valorem.
The applicable subheading for the LH-54 automatic rotary bottle washing machine will be 8422.20.0000, HTSUS, which provides for Machinery for cleaning or drying bottles or other
Containers. The rate of duty will be Free.
The applicable subheading for the two side bottle labeling machine will be 8422.30.9120, HTSUS, which provides for Machinery for filling, closing, sealing or labeling bottles, cans, boxes, bags or other containers; machinery for capsuling bottles, jars, tubes and similar containers; machinery for aerating beverages: Other: Labeling machines. The rate of duty will be Free.
The applicable subheading for the conveyor belt will be 8428.33.0000, HTSUS, which provides for Other lifting, handling, loading or unloading machinery (for example, elevators, escalators, conveyors, teleferics): Other continuous-action elevators and conveyors, for goods or materials: Other, belt type. The rate of duty will be Free.
The applicable subheading for the semi-automatic bottle blowing machine will be 8477.30.0000, HTSUS, which provides for Machinery for working rubber or plastics or for the manufacture of products from these materials, not specified or included elsewhere in this chapter; parts thereof: Blow-molding machines. The rate of duty will be 3.1 percent ad valorem.
The applicable subheading for the tanks that contain agitators will be 8479.82.0040, HTSUS, which provides for Machines and mechanical appliances having individual functions, not specified or included elsewhere in this chapter, parts thereof: Other machines and mechanical appliances: Mixing, kneading, crushing, grinding, screening, sifting, homogenizing, emulsifying or stirring machines: Mixing, kneading or stirring machines. The rate of duty will be free.
Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.
Your inquiry does not provide enough information for us to provide a classification ruling on whether the goods, when imported together in one shipment, comprise a functional unit. Please submit the following information:
Re the LH-12 vodka automatic filling machine, does the filling involve vacuum or gas packaging?
Re the light inspector, (a) Are there optical elements incorporated in the light inspector. Optical elements are lenses, prisms, beam splitters, etc. (b) What is the light source? (c) Provide schematic diagram of the light inspector and (d) How does the light inspector perform the inspection to determine whether there are impurities or particulate matter?
Re the XG-1 automatic cap screwing machine, does the capping involve vacuum or gas packaging?
Re the automatic date printing machine, is the date printing machine capable of connecting to an automatic data processing machine or to a network? Please explain.
Re the semi-automatic bottle wrapping machine the semi-automatic bottle wrapping machine also heat seal? and
Re the speed control power unit, (a) What is the principal function of the speed control power unit? Is it designed for switching or protecting electrical circuit? If so, please explain in detail. (b) Is the motor included at time of importation? Is it a part of this unit? (c) As imported, is the unit equipped with two or more apparatus of heading 8535 or 8536 for electric control or distribution of electricity such as switches, relays, fuses surge suppressors, plugs, sockets, lamp-holders and other connectors or junction boxes? Please provide a list of all the components within the unit and (d) Provide labeled, exploded view diagram, which identifies all the internal and external components that makes-up this unit.
Are the tanks included in the same shipment as the other machines or are they always shipped separately? Where in the production line are the tanks located? Submitted schematic of the line does not show the tanks. Please include a schematic that shows the tanks?
Is the plastic material always shipped separately?
In the submitted schematic, the bottle blowing machine and shrink wrapping machine do not appear to be physically connected to the other machines by the conveyor belt. Are these free-standing machines? If so, how are the bottles transferred from the bottle blowing machine to the bottle washing machine and from the date printing machine to the shrink wrapping machine?
When this information is available, you may wish to consider resubmission of your request. We are returning any related samples, exhibits, etc. If you decide to resubmit your request, please include all of the material that we have returned to you.
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,
Gwenn Klein Kirschner
Acting Director
National Commodity Specialist Division