CLA-2-84:RR:NC:1:104 I81274

Mr. Nigel P. Cotterill
Salvagnini America. Inc.
27 Bicentenial Court
Hamilton, OH 45015

RE: The tariff classification of a laser cutting machine, metal bending machine and bending machine parts from Italy or Austria.

Dear Mr. Cotterill:

In your letter dated April 17, 2002 you requested a tariff classification ruling.

The L2 2D laser cutting system is used to process 3000 x 1500 mm sheet metal blanks in two dimensions. In addition to the CO2 laser source, the unit includes a table changing system and a robot to load and unload the blanks. The robot will be imported with the end of arm tooling (suction cups). The table changing system has two tables with grills. The workpieces are placed on these tables so that when one table is in the work zone inside the machine structure, the other is outside so parts can be loaded and unloaded without stopping production.

The Robo-Former is a numerically controlled bending cell consisting of a bending press, 6-axis anthromorphic robot and stations for inputting materials, centering, and panel regripping and unloading. The robot takes the sheet to be machined from the pack on the feeding station and places it on the centering station. During the bending cycle, the sheet is held by the robot which acts as a manipulator. The regripping station allows the robot to change the robot’s grip on the panel for further bending. At the end of the process, the robot stacks the panels.

The toolsteel segments are parts of the P4 bending machine’s blankholding system. The blankholder holds the sheet metal blank (or “panel”) in place while the upper and lower bending tools bend the metal. (By “panels” Salvagnini means sheets of metal bent one or more times along one or more sides.) You have indicated that a blankholder consists of 60 to 100 segments, depending on the size of the bending machine. Sometimes a few segments are imported to replace damaged ones and in other case a complete blankholder will be imported.

The applicable subheading for the L2 Laser Cutting System will be 8456.10.1010, Harmonized Tariff Schedule of the United States (HTS), which provides for machine tools for working any material by removal of material, by laser …: operated by laser or other light or photon beam processes: for working metal. The rate of duty will be 3.5 percent.

The applicable subheading for the Robo-Former bending cell will be 8462.21.8085, HTS, which provides for machine tools (including presses) for working metal by bending, folding, straightening or flattening The rate of duty will be 4.4 percent.

The applicable subheading for the complete blankholder will be 8466.20.8035, 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 rate of duty will be 3.7 percent.

Separately imported segments for a blankholder will be classified under HTS subheading 8466.94.8585 which provides for parts for machines of heading 8462 or 8463: other: other: other. The rate of duty will be 4.7 percent.

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