CLA-2-84:RR:NC:1:104 F86966
Mr. Nigel P. Cotterill
Salvagnini America, Inc.
27 Bicentennial Court
Hamilton, OH 45015
RE: The tariff classification of various metal-working machine tools and handling machinery from Austria and Italy.
Dear Mr. Cotterill:
In your letter dated May 10, 2000 you requested a tariff classification ruling.
The S4 Sheet Metal Punching and Shearing Center (Models S4.25, S4.30 and S4.40) incorporates both punching and shearing in a single process and in one machine frame. The unit features hydraulic punching with up to 96 tool stations. Each tool has its own ram eliminating tool change time. The right angle shear featuring 400x400 (15.75”x15.75”) blades is incorporated within the punching machine. The S4 is used by both job shops and OEM companies to manufacture single parts, families of parts, and/or dynamically nested parts to meet daily schedules in a just-in-time (“JIT”) environment. The unit also features online diagnostics and programming software.
The P4 Sheet Metal Automatic Bending System (Models P4-1812, P4-2512, P4-3212, P4-2220 and P4-2520) produces unlimited positive and negative bends and complicated and contoured shapes without tool changes. The unit’s accuracy of bend location is ±0.004” with an angle repeatability of 0.5o.
The P2/Performer Sheet Metal Automatic Bending System is a compact Panel Bender. The bending unit consists of two bending blades, an adjustable blankholder and a counter-blade. The unit is capable of making an unlimited number of up and down bends and can use the same tools to process sheets of different lengths and/or thicknesses. The blank is handled by a manipulator/rotator which rotates the blank by 90o, 180o and 270o automatically. Other features include a CNC controller and programming software. Machine weight is 30,870 lbs. and its dimensions are 90.6”W x 220.5”L x 94.5”H.
The CSR Robotizied Loading and Unloading Device (Models CSR-18 and CSR-25) is designed to be used with the S4 Sheet Metal Punching and Shearing Center and the P4 Panel Benders. The device performs “pick & place” operations. It features two distinct work cycles, one for feeding a prepunched blank ready to be bent and one for unloading finished panels. The models CSR-18 and CSR-25 basically consist of a robot body, an adjustable pick-up device with suction cups for handling, loading or unloading all types of panels, and a controller. The CSR-18 features 5 axes of movement while the CSR-25 features 6 axes.
The MD3015.P.CONV1.M15 Tower Storage System is used for the automatic storage and handling of sheet metal. The system features a stand with 15 shelves (M15) on which the sheets are stored, a unidirectional brush conveyor (CONV1) for feeding single sheets and a manipulator-elevator used for picking up sheets and depositing them on the shelves or on the conveyor. Each shelf is capable of storing 1 or 2 packs of sheet metal. Sheet metal is initially loaded from the rear side (P) either by depositing a pack of sheets on the automatic loading shelf by a forklift truck or by depositing a single sheet directly onto the conveyor. A pack can be loaded during the handling of sheets already present inside the storage system. Once placed on the conveyor, the sheets are fed to a downstream processing machine such as a S4 Punching-Shearing Center. The system includes a software package for the automatic management of the system allowing the sheet metal to be loaded, unloaded or moved to the shelves of the storage system.
With the exception of the P4 Sheet Metal Automatic Bending System, all the units are manufactured in Italy. The P4 Sheet Metal Automatic Bending System is manufactured in Austria.
The applicable subheading for the S4 Sheet Metal Punching and Shearing Center (Models S4.25, S4.30 and S4.40) will be 8462.41.0080, Harmonized Tariff Schedule of the United States (HTS), which provides for Machine tools (including presses) for working metal by forging, hammering or die-stamping; machine tools (including presses) for working metal by bending, folding, straightening, flattening, shearing, punching or notching; presses for working metal or metal carbides, not specified above: Punching or notching machines (including presses), including combined punching and shearing machines: Numerically controlled…Other. The rate of duty will be 4.4 percent ad valorem.
The applicable subheading for the P4 Sheet Metal Automatic Bending System (Models P4-1812, P4-2512, P4-3212, P4-2220 and P4-2520) and the P2/Performer Sheet Metal Automatic Bending System will be 8462.21.8085, HTS, which provides for Machine tools (including presses) for working metal by forging, hammering or die-stamping; machine tools (including presses) for working metal by bending, folding, straightening, flattening, shearing, punching or notching; presses for working metal or metal carbides, not specified above: Bending, folding, straightening or flattening machines (including presses): Numerically controlled: Other…Other The rate of duty will be 4.4 percent ad valorem.
When imported separately, the CSR Robotizied Loading and Unloading Device (Models CSR-18 and CSR-25) consisting of the robot together with its end-of–arm tooling (i.e., the pick-up device with suction cups) and its controller is a functional unit classifiable in 8428.90.0010, HTS, which provides for Other lifting, handling, loading or unloading machinery: Other machinery…Other: Industrial robots. The rate of duty will be Free.
The applicable subheading for the MD3015.P.CONV1.M15 Tower Storage System, when imported separately, will be 8428.90.0090, HTS, which provides for Other lifting, handling, loading or unloading machinery: Other machinery…Other: Other. The rate of duty will be Free.
When imported together with a specific machine tool, the CSR Robotizied Loading and Unloading Device (Models CSR-18 and CSR-25) (in the configuration noted above) and/or the MD3015.P.CONV1.M15 Tower Storage System together with its respective machine is classified as a functional unit under the HTS subheading appropriate to that machine tool.
Numerous references to software are made throughout the submitted literature. It is not clear whether or not this software will be included with the machines at time of importation. In accordance with Legal Note 6 to Chapter 85, HTS, software is required to be classified in the appropriate subheadings of heading 8524, whether or not the software is entered with the apparatus for which it is intended. Your inquiry does not provide sufficient information for us to render a classification ruling on the software. Your request for a classification ruling on the software should include information on the inherent character of the software, the type of carrier medium being used (e.g., floppy disk) and details on method of shipment (i.e., shipped with its respective machine or shipped separately). When this information is available, you may wish to consider resubmission of your request on the software.
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