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NY 890488




Oct. 7, 1993

CLA-2-84:S:N:N1:103 890488

CATEGORY: CLASSIFICATION

TARIFF NO.: 8428.90.0010

Ms. Michele M. Maga
Fanuc Robotics North America, Inc.
2000 South Adams Road
Auburn Hills, MI 48326-2800

RE: The tariff classification of robots from Japan

Dear Ms. Maga:

In your letter dated September 10, 1993 you requested a tariff classification ruling.

The LR (Loader Robot) series of robots is composed of the LR-Mate, LR-1, and LR-0 robots. The LR-Mate is a free-standing robot designed to load and unload workpieces from a machine tool, as well as perform palletizing operations. It utilizes an arm, powered by an AC servo-motor, with 5 axes of articulation and a repeatability of .07 millimeter. The LR-1 is a lightweight, 4 axis electric servo driven robot designed for loading and unloading of CNC lathes. It may be mounted on the floor or on the machine tool itself. The LR-1 can hold objects weighing up to 35 kilograms, and features .1 millimeter repeatability. The LR-0 is a simpler version of the LR-1, featuring 3 axes of motion, a payload capacity of four kilograms, and a repeatability of .05 millimeter.

In your letter you state that these robots are used with either the Fanuc Robotics RJ-Mate controller, or with the GEFanuc series 18T or 16T controllers. Due to the design of these controllers and their software, they are unable to support more complex, higher level programming languages which are necessary for performing more difficult functions. You also state the LR series robots only utilize simple end of arm tooling, and cannot be fitted with more sophisticated tooling. Therefore, these robots can only perform loading, unloading and palletizing operations, and are marketed as such.

Based on the above information, the applicable subheading for the LR-Mate, LR-1, and LR-0 robots will be 8428.90.0010, Harmonized Tariff Schedule of the United States (HTS), which provides for other lifting, handling, loading or unloading machinery: other machinery: other: industrial robots. The rate of duty will be 2 percent ad valorem.

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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