CLA-2-84:RR:NC:1:104 H81443
Mr. Kent Sunakoda
James J. Boyle & Co.
2525 Corporate Place, #100
Monterey Park, CA 91754
RE: The tariff classification of thermal bonding lines for nonwoven products from Korea.
Dear Mr. Sunakoda:
In your letter dated May 17, 2001 on behalf of SkyvivaUS Inc. of Los Angeles, California you requested a tariff classification ruling.
Your client will be importing four thermal bonding lines for nonwovens, two lines with needle punching and heat pressing machines and two lines without. All machines contained in a manufacturing line will arrive on the same vessel. The lines will consist of the following machines:
Lines with needle punch and heat press: Lines without:
1. weighing feeder weighing feeder
2. conveyor feeder conveyor feeder
3. beak opener beak opener
4. mixing hopper mixing hopper
5. chute hopper & scale unit chute hopper & scale unit
6. carding machine carding machine
7. cross layer cross layer
8. needle puncher thermal bonding oven
9. thermal bonding oven cooler
10. heat press side cutter & cross cutter
11. cooler 2nd opener
12. side cutter & cross cutter auto stacker
13. 2nd opener auto packer
14. auto stacker
15. auto packer
The nonwoven product in this instance will be polyester insulation. The raw material includes polyester staple fiber (PSF) and low melting fiber (LMF). The first seven machines prepare the fibers leading to the formation of a web of the desired thickness before the bonding process begins. The lines incorporating needle punching and heat pressing in addition to thermal bonding produce acoustical non-woven products that are thinner and possess a more rigid texture than products made by the lines without these machines.
The thermal bonding is accomplished by hot air circulation with the product carried through the oven on a mesh belt conveyor. The needle puncher is a mechanical bonding machine which produces fiber entanglement. Mechanical bonding is often used as the initial stage of bonding followed by thermal bonding to give additional properties. The heat pressing adds strength and density to the product. After bonding, the product is cooled, cut to size, stacked and then stuffed into a plastic package and sealed by an auto packing machine.
The thermal bonding lines, with and without the needle puncher and heat press, (but not including the auto packer) are classified as functional units under subheading 8449.00.5000, Harmonized Tariff Schedule of the United States (HTS), which provides for machinery for the manufacture of felt or nonwovens in the piece or in shapes …: other. The rate of duty will be free.
The auto packing machines are classified separately under HTS subheading 8422.30.90 which provides for machinery for filling, closing, sealing or labeling bottles, cans, boxes, bags or other containers: 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