CLA-2-84:RR:NC:1:103 F80533
Mr. Don Page
Fuji America Corporation
171 Corporate Woods Parkway
Vernon Hills, IL 60061
RE: The tariff classification of feeders from Japan
Dear Mr. Page:
In an undated letter which we received on Dec. 6, 1999 you requested a tariff classification ruling.
In your letter you described three types of articles which are used to feed components referred to as surface mount devices to placement machines which assemble them onto a printed circuit board (PCB). These components, consisting of resistors, capacitors, integrated circuits, and similar electrical devices, arrive at the placement machine affixed into a series of pockets in a paper or plastic tape which has been wound onto a reel. For the standard feeder the placement machine operator mounts the reel onto the feeder. The tape containing the components is then threaded through the feeder, and the feeder is snapped into position on the placement machine. Following the instructions of its program, the placement machine will depress a lever on the feeder to mechanically advance the tape one pocket, thus exposing a component for pickup off the tape and placement onto the PCB by the placement machine.
The motor feeder performs the same function as the standard feeder, but incorporates a small stepper motor to move the tape forward. The power feeder is similar to the motor feeder, and also contains an electric cable which allows the power feeder to communicate with the placement machine regarding the type of component mounted on the feeder, the feeder serial number, and the number of placements which have occurred. This data is passed from the placement machine through a LAN network to a central computer, and is used for quality control and inventory purposes. You stated that all three types of feeders are specifically designed for and solely used with Fuji surface mount equipment.
In your letter you claimed that all three types of feeders should be classified in subheading 8479.90.9595, Harmonized Tariff Schedule of the United States (HTS), which provides for parts of machines and mechanical appliances having individual functions, not specified or included elsewhere (in Chapter 84): other: other: other. The motor feeder and power feeder each have an individual function because they are capable of feeding in and of themselves, and feeding is a function which can be performed by machines operating independently of any other machine. Therefore the motor feeder and the power feeder are classifiable under subheading 8479.89.9797, HTS, which provides for machines and mechanical appliances having individual functions, not specified or included elsewhere (in Chapter 84): other machines and mechanical appliances: other : other: other: other. The rate of duty will be 2.5 percent ad valorem.
On the other hand, the standard feeder plays an integral part in the operation of the placement machine and is incapable of performing its function of feeding without the assistance of the placement machine, which trips a lever on the feeder to advance the tape. The standard feeder thus does not have an individual function. Accordingly, the applicable subheading for the standard feeder will be 8479.90.9595, Harmonized Tariff Schedule of the United States (HTS), which provides for parts of machines and mechanical appliances having individual functions, not specified or included elsewhere (in Chapter 84): other: other: other. The rate of duty will be free.
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 Alan Horowitz at 212-637-7027.
Sincerely,
Robert B. Swierupski
Director,
National Commodity
Specialist Division