CLA-2-84:OT:RR:NC:N1:104
Mr. Jean-Claude Excoffier
HP Inc.
150 Route du Nant d’Avril
Meyrin
Switzerland
CH1217
RE: The tariff classification of HP Jet Fusion 3D Printing Solution from Singapore
Dear Mr. Excoffier:
In your letter dated October 17, 2017 you requested a tariff classification ruling.
The HP Jet Fusion 3D Printing Solution is a complete system that produces 3D objects using cartridges containing plastic powder materials and fluids. The three individual machines that make up the HP Jet Fusion 3D Printing Solution work together to produce 3D objects using HP Multi Jet Fusion Technology.
The individual machines that makes up the HP Jet Fusion 3D Printing Solution are: the HP Jet Fusion 3D Printer, the HP Jet Fusion 3D Processing Station and the HP Jet Fusion 3D Build Unit. The HP Jet Fusion 3D printer is the main element of the system. The printer performs the final 3D printing operation. The HP Jet Fusion 3D Processing Station performs a variety of steps such as controlling the cooling time of the item that was formed and assisting in the unpacking of the article from the powder bed. The Processing Station also screens the powder to eliminate any impurities, mixes powder and loads the mix into the Build Unit in order to prepare for a new job. The HP Jet Fusion 3D Build Unit carries the powder to the 3D printer and returns the newly built 3D article in a solid block. The Build Unit moves the 3D article on for cooling after the job is completed in order to allow a continuous printing process.
You have requested a ruling as to the tariff classification the HP Jet Fusion 3D Printer, the HP Jet Fusion 3D Processing Station and the HP Jet Fusion 3D Build Unit under the following two scenarios: (A) the HP Jet Fusion 3D Printing Solution when imported complete in one shipment and (B) the three individual machines when imported separately.
Note 4 to Section XVI, Harmonized Tariff Schedule of the United States (HTSUS), addresses functional units. The note states “Where a machine...consists of individual components (whether separate or interconnected by piping, by transmission devices, by electric cables or by other devices) intended to contribute together to a clearly defined function covered by one of the headings in chapter 84 or chapter 85, then the whole falls to be classified in the heading appropriate to that function”. Regarding scenario A, the HP Jet Fusion 3D Printer, the HP Jet Fusion 3D Processing Station and the HP Jet Fusion 3D Build Unit, when imported together in one shipment, contribute together to the clearly defined function of additive manufacturing/3D printing. Therefore, in accordance with Note 4 to Section XVI, the applicable subheading for the HP Jet Fusion 3D Printing Solution, imported complete in one shipment, will be 8477.80.0000, 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: Other machinery. The rate of duty will be 3.1 percent ad valorem.
With regard to scenario B, your inquiry does not provide enough information for us to give a classification ruling on the three machines when imported separately. Please provide an operator’s/installation manual for each machine which provides a step-by-step description of the unit’s method of operation. Submitted literature on the HP Jet Fusion 3D 4200/3200 Printing Solution shows the HP Jet Fusion 3D Build Unit as item #9. While the picture shows the Build Unit physically located within the HP Jet Fusion 3D Processing Station, in the corresponding description, the Build Unit is said to be “included within the printer”. Please explain. Are the external tanks included with the Processing Station? When this information is available, you may wish to consider resubmission of your request.
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 https://hts.usitc.gov/current.
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 [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division