CLA-2-84:RR:NC:1:104 F84043
8308.20.6000
Mr. Karl Krueger
AEI Customs Brokerage Services
P.O. Box 5129
Southfield, Michigan 48086-5129
RE: The tariff classification of hydraulic self-piercing riveting tools and tubular rivets from England.
Dear Mr. Krueger:
In your letter dated March 1, 2000 on behalf of Henrob Corporation of Farmington Hills, Michigan you requested a tariff classification ruling.
The complete hand operated hydraulic self-piercing riveting tool consists of a “C” frame, a rivet setter and an external hydraulic power pack. The rivets used with the tool are also imported. While Henrob imports all of these components, they often do not import them as complete systems. They import the components in varying quantities.
The self-piercing rivet setter is mounted in a C-frame. The rivet setter essentially consists of a double acting hydraulic cylinder which advances and retracts a punch. The punch in turn actuates the rivet feeding mechanism. Collated rivets are presented under the punch on a plastic belt. The punch pushes each rivet out of the belt, through the nose of the rivet setter and into the material being joined. After passing through the material, the rivet is formed by an upsetting die into a shape which locks it in position and joins the material together. The upsetting die is mounted in the base of the C-frame. The hydraulic cylinder is pressurized by a separate electrically driven power pack, which also controls the sequencing of the rivet setter. The rivet setter may be suspended from a counter balance on an overhead tracking system.
The power pack is the unit that powers the whole tool. It consists of a 10 HP multi-phase AC electric motor, a hydraulic gear pump, control valve and oil tank housed in a metal cabinet approximately 2’ x 3’. The cabinet can be mounted on castors for complete mobility.
A sample of the rivets was obtained. The sample is a strip of collated tubular steel rivets. You have stated that they are neither lathed nor machined. They are cold forged. The rivets are imported in their spools or magazines which are disposed of when the rivets are expended. The spools may hold as many as 5,000 rivets. The brochure indicates that they may be made of copper or aluminum in addition to steel. The spool can be mounted onto an overhead tool balancer.
The applicable subheading for the complete self-piercing riveting system (rivet setter, C-frame and hydraulic power pack) will be 8467.89.1000, Harmonized Tariff Schedule of the United States (HTS), which provides for tools for working in the hand, pneumatic, hydraulic or with self-contained non-electric motor …: other tools: other: suitable for metal working. The rate of duty will be free.
The applicable subheading for separately imported “C” frames and separately imported rivet setters will be 8467.99.0090, HTS, which provides for other parts of tools for working in the hand.
The applicable subheading for separately imported external hydraulic power packs will be 8413.60.0030, HTS, which provides for other rotary positive displacement pumps, hydraulic fluid power pumps, gear type. The rate of duty will be free.
The applicable subheading for the tubular rivets of iron or steel will be 8308.20.3000, HTS, which provides for tubular or bifurcated rivets: of iron or steel and not brightened, not lathed and not machined. The rate of duty will be free.
The tubular rivets of base metal other than iron or steel are classifiable under HTS subheading 8308.20.6000 which provides for tubular or bifurcated rivets: 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 Robert Losche at 212-637-7038.
Sincerely,
Robert B. Swierupski
Director,
National Commodity
Specialist Division