CLA-2-84:OT:RR:NC:N1:104
Laurel Scapicchio
Desktop Metal, Inc.
63 3rd Avenue Burlington, MA 01803
RE: The tariff classification of a 3D Powder Station from China
Dear Ms. Scapicchio:
In your letter dated August 3, 2023, you requested a tariff classification ruling.
The Shop System Powder Station, Model SHP-PD0001 (“Powder Station”), is a component or module of the Desktop Metal Shop System, a system that produces 3D printed objects by employing metal powder materials. The separate components or modules that comprise the Desktop Metal Shop System are: (1) 3D Printer; (2) Drying Oven; (3) Powder Blender; (4) Vacuum; and (5) Powder Station. These components work together to produce 3D objects. All modules of the Metal Shop System, including the Powder Station, are imported separately.
The Powder Station is a cabinet-like unit on wheels, measuring approximately 63 x 48 x 28 inches and weighing 310 kg. The main components of the Powder Station are electronics, LCD screen, depowder chamber, hand-held-air pick, powder sieve, powder mixing keg, and scale. The unit’s function is to separate 3D printed parts from the surrounding loose powder in the build box and recycle the loose powder for reuse. Bulk and fine depowdering are accomplished via a hand air pick.
The Powder Station is claimed to be designed specifically for the 3D Printer and essential for the functioning of the Desktop Metal Shop 3D Printer system. As part of the Shop System’s production cycle, a build box containing parts printed by the 3D Printer are dried in the Drying Oven and then moved into the Powder Station’s chamber, where depowdering takes place. Loose powder first passes through the filter at the bottom of the depowder chamber into the bottom cabinet of the Powder Station and then through the powder doser, which controls the feed of the loose powder through the powder sieve. Agglomerated powder is sieved out to remove impurities, and the remaining loose powder is collected in a powder keg for storage and/or reuse in future 3D print jobs. Reused powder must first be processed using the Powder Blender module of the Desktop Metal Shop System. Finally, the user removes the depowdered parts from the depowder chamber and places them into a metal furnace for sintering.
In your request, you suggest classification of the Powder Station in subheading 8485.10.0100, Harmonized Tariff Schedule of the United States (HTSUS), providing for “Machines for additive manufacturing: By metal deposit.” We disagree. In accordance with Note 2(b) to Section XVI, HTSUS, the applicable subheading for the Shop System Powder Station, Model SHP-PD0001, will be 8485.90.9000, HTSUS, which provides for “Machines for additive manufacturing: Parts: Other.” 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 at https://hts.usitc.gov/current.
The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP.
This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection 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, please contact National Import Specialist Arthur Purcell at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division