CLA-2-84:RR:NC:1:104 R00175
Mr. John Carrier
Central Purchasing, Inc.
3491 Mission Oaks Blvd.
Camarillo, CA 93012
RE: The tariff classification of tools, workholders, etc. from Taiwan, India and China
Dear Mr. Carrier:
In your letter dated March 11, 2004 you requested a tariff classification ruling.
You have indicated via e-mail that all of the following items are imported packaged for retail and that nothing is added after importation.
The drill bit sharpener, SKU 34245, is a plastic holder for drill bits to be sharpened. The set includes a holding fixture plus 4 collets to hold 4 size ranges of bits. The bit is placed and secured in the collet and then moved to a bench grinder or drill press. The item does not sharpen a tool. It merely holds the tool in position to be sharpened. In effect, the drill bit in this situation is the workpiece, not the tool. This device is a workholder rather than a tool holder. The C/O is Taiwan.
The bullnose live center, SKU 40090, is a stainless steel precision center used in lathes for supporting parts or open-ended tubing as small as ½” diameter or as large as 2 ½” diameter. The C/O is India.
The spotweld cutter set, SKU 2553, is used in drill presses for drilling out spotwelds without damage to the surrounding sheet metal. It includes two cutting tools mounted on ¼” arbors with retracting pilot pins, an additional two 3/8” and two 5/16” unmounted doubles sided cutters, two extra retracting pilots and an Allen wrench in a blow molded plastic case with cavities for each tool. The cutters are made of high speed steel (HSS). The C/O is Taiwan.
The professional parting tool, SKU 37034, is used in smaller lathes for working metals. It includes the high speed steel (HSS) parting blade mounted in a tool holder and a hex wrench. A parting tool is used to part or cut off a workpiece from the remaining bar stock fed into a lathe after the stock has been machined with a turning tool. The C/O is India. You have also inquired about separately imported replacement blades without the holder. (Your website describes a 5-pack of replacement parting blades, SKU 37035.)
The Explanatory Notes to the HTS for heading 8208 indicate that the heading applies to unmounted knives or cutting blades for machines or mechanical appliances.
The mechanics stethoscope, SKU 41966, is used in identifying various engine failures and body squeaks. The two piece probe reaches 11 ¾”. The C/O is China.
The applicable subheading for the spotweld cutter set, SKU 2553, will be 8207.50.2080, Harmonized Tariff Schedule of the United States (HTS), which provides for interchangeable tools for handtools, whether or not power operated, or for machine tools … tools for drilling, other than for rock drilling, and parts thereof: with cutting part containing by weight over 0.2 percent of chromium, molybdenum, or tungsten or over 0.1 percent vanadium. The rate of duty will be 5 percent.
The applicable subheading for the professional parting tool set, SKU 37034, will be 8207.90.3085, (HTS), which provides for interchangeable tools for handtools, whether or not power operated, or for machine tools … :other: cutting tools with cutting part containing by weight over 0.2 percent of chromium, molybdenum, or tungsten or over 0.1 percent vanadium. The rate of duty will be 5 percent.
Separately imported replacement blades for the parting tool, SKU 37035, will be classified under 8208.10.0060, HTS, which provides for knives and cutting blades, for machines or for mechanical appliances, and base metal parts thereof: for metal working, and parts thereof. The rate of duty will be free.
The applicable subheading for the drill bit sharpener, SKU 34245, and the bullnose live center, SKU 40090, will be 8466.20.80, HTS, which provides for parts and accessories suitable for use solely or principally with the machines of headings 8456 to 8465, including work or tool holders, … : work holders: other. (The statistical reporting suffix will be 20 for the drill bit sharpener and 35 for the bullnose live center.) The rate of duty will be 3.7 percent.
The applicable subheading for the mechanics stethoscope, SKU 41966, will be 9031.80.8085, HTS, which provides for other, non-optical measuring or checking instruments, appliances and machines. The rate of duty will be 1.7 percent.
Articles classifiable under subheading 8466.20.8035 and 8207.90.3085, HTS, which are products of India may be entitled to duty free treatment under the Generalized System of Preferences (GSP) upon compliance with all applicable regulations. The GSP is subject to modification and periodic suspension, which may affect the status of your transaction at the time of entry for consumption or withdrawal from warehouse. To obtain current information on GSP, check our Web site at www.cbp.gov and search for the term "GSP".
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 Robert Losche at 646-733-3011.
Sincerely,
Robert B. Swierupski
Director,
National Commodity
Specialist Division