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NY 869799


JANUARY 10, 1991

CLA-2-90:S:N:N1:114 869799

CATEGORY: CLASSIFICATION

TARIFF NO.: 9031.40.0080

Ms. Karen Carpenter
Zygo Corporation
Laurel Brook Road
P. O. Box 448
Middlefield, Connecticut 06455-0448

RE: The tariff classification of the 3100 Series Part Profiling System from France

Dear Ms. Carpenter:

In your letter dated November 21, 1991 you requested a tariff classification ruling.

The 3100 Series Part Profiling System is a system for measuring precision ground parts and parts turned on CNC lathes. Applications include aerospace parts, aircraft components and engine parts, armaments, brake components, automotive shafts, steering gears, transmission parts, and the like.

The 3100 Series part Profiling System operates by scanning a part with a laser micrometer. The position and diameter of the part are recorded by a computer. The operator then inputs the exact length of the part by defining the beginning and end of the part. At this point, a drawing exists in the computer's memory. The operator uses this drawing to define any measurements that need to be performed on the part: diameter, length, radius of curvature, taper angle, straightness, roundness, and runout. The 3100 Series Part Profiling System is called the Optodim system in Europe.

The 3100 Series Part Profiling System may be imported with the HP Vectra 286/12 Computer or without a computer, depending on the customer's needs.

The applicable subheading for the 3100 Series Part Profiling System imported with or without a computer will be 9031.40.0080, Harmonized Tariff Schedule of the United States (HTS), which provides for Measuring or checking instruments, appliances and machines, not specified or included elsewhere in this chapter; Other optical instruments and appliances; Other. The rate of duty will be 10 percent ad valorem.

You have indicated that one component of the system, the model 1201B Bench Gauge, is manufactured in the United States and shipped to France for integration in the 3100 Series Part Profiling System. We cannot advise as to the applicability of Heading 9802, Harmonized Tariff Schedule of the United States (HTS), which covers American Goods Assembled Abroad, without further information regarding the operations performed in France to integrate the Bench Gauge into the Part Profiling System.

This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177).

A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction.

Sincerely,

Jean F. Maguire
Area Director

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