CLA-2-84:OT:RR:NC:N1:105
Kristen Fannon UWL Inc. 1340 Depot Street Rocky River, OH 44116
RE: The tariff classification of an automatic powder coating line from Turkey
Dear Ms. Fannon:
In your letter dated May 9, 2024, on behalf of your client, Spray Tech Industrial Solutions, Inc., A Combined Finishing Company, you requested a tariff classification ruling.
The merchandise under consideration is described as an automatic powder coating line. The line includes a pre-treatment system, drying oven, powder coating booth, curing oven, and conveyor system. Once the individual systems are installed and integrated, the function of the entire line is to apply a powdered coating to metal parts. Each system, described below, is imported unassembled but has all of the necessary items to complete the system. Roughly 121 feet by 59 feet by 18 feet of floor space is required for the complete coating line.
The pre-treatment system consists of stainless-steel tanks, water circulation pumps, heated tanks, and a stainless-steel tunnel, which is equipped with spray nozzles and a cascading water system. The purpose of the pre-treatment system is to clean and treat metal parts while they are conveyed through the tunnel. Using jet sprayers, each metal part is sprayed with a cleaning liquid to provide a conversion coating and then rinsed by cascading water.
The drying tunnel oven utilizes convection heating to dry and remove any remaining water content from the metal parts after they leave the pre-treatment system. It is described as a direct fire natural gas oven measuring approximately 32.8 feet in length. The tunnel is constructed of metal panels lined with rock wool and equipped with a burner and circulating fan that raises the temperature of the tunnel up to 110 degrees Celsius (230 degrees Fahrenheit).
The powder coating booth is an enclosure that uses electrostatic technology and automatic detecting spray guns to apply powder to a metal part. A low voltage is supplied to the spray guns, which charges the powder as it is discharged from the gun, causing the powder to adhere to the metal parts. The booth consists of a PVC booth that is equipped with exhaust and filter systems, powder transfer systems, spray guns, a 3D coating set, and a control module.
The curing oven is described as a U-turn natural gas oven that consists of a chamber enclosed by panels made of insulated rock wool sandwiched by galvanized metal sheets. The oven contains two lanes, with each measuring approximately 73.8 feet in length. The oven operates based on convection heating and is equipped with a natural gas heating unit capable of raising the internal temperature of the chamber up to 250 degrees Celsius. The oven is used to cure the newly applied powder coating by converting the dry powder into a gel, which becomes the finished coating.
The conveyor system is described as an overhead webb chain conveyor that transports metal parts throughout the entire automatic powder coating line. It moves at a speed of three feet per minute and has a rail system with an overall length of 457 feet. The conveyor uses a drive unit to move suspended materials along webb-type chains equipped with trolleys that are spaced 613 millimeters apart along the chain, each having a 240-kilogram capacity. The conveyor transports parts through the pre-treatment system, drying oven, powder coating booth, and curing oven.
When imported together in a single shipment, and in accordance with 19 CFR 147.57 and 19 CFR 141.58, the individual systems of the automatic powder coating line form a functional unit that contributes together to the clearly defined function of applying powder to coat metal.
Section XVI Note 4 states: Where a machine (including a combination of machines) 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.
In accordance with Note 4 to Section XVI, the applicable subheading for the complete automatic powder coating line, when imported with all sub-systems, will be 8424.89.9000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Mechanical appliances (whether or not hand operated) for projecting, dispersing or spraying liquids or powders; fire extinguishers, whether or not charged; spray guns and similar appliances; steam or sand blasting machines and similar jet projecting machines; parts thereof: Other appliances: Other. The general rate of duty will be 1.8 percent ad valorem.
The applicable subheading for the pre-treatment system and powder coating booth, when separately imported, will be 8424.89.9000, HTSUS, which provides for Mechanical appliances (whether or not hand operated) for projecting, dispersing or spraying liquids or powders; fire extinguishers, whether or not charged; spray guns and similar appliances; steam or sand blasting machines and similar jet projecting machines; parts thereof: Other appliances: Other. The general rate of duty will be 1.8 percent ad valorem.
The applicable subheading for the drying tunnel oven, when separately imported, will be 8419.39.0280, HTSUS, which provides for Machinery, plant or laboratory equipment, whether or not electrically heated (excluding furnaces, ovens and other equipment of heading 8514), for the treatment of materials by a process involving a change of temperature such as heating, cooking, roasting, distilling, rectifying, sterilizing, pasteurizing, steaming, drying, evaporating, vaporizing, condensing or cooling, other than machinery or plant of a kind used for domestic purposes; instantaneous or storage water heaters, nonelectric; parts thereof: Dryers: Other: Other. The general rate of duty will be free.
The applicable subheading for the curing oven, when separately imported, will be 8417.80.0000, HTSUS, which provides for Industrial or laboratory furnaces and ovens, including incinerators, nonelectric, and parts thereof: Other, except parts. The general rate of duty will be 3.9 percent ad valorem.
The applicable subheading for the conveyor system, when separately imported, will be 8428.39.0000, 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. The general 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/.
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 Jason Christie at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division