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NY A85614

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July 24, 1996

CLA-2-82:RR:NC:GI:115 A85614

CATEGORY: CLASSIFICATION

TARIFF NO.: 8207.30.6090; 7320.20.5045; 7318.22.0000; 7318.24.0000; 8479.89.9598

Mr. Kelly Spivey
Southern Overseas
3333 Piper Lane
Charlotte, NC 28208

RE: The tariff classification of presses, tools and tool parts from England.

Dear Mr. Spivey:

In your letter dated June 24, 1996, you requested a tariff classification ruling.

The subject items are described as follows:

1) Mini Die Tools, models 03HT-A-030 and TOL 1230 - They are used on mechanical presses and are interchangeable depending on the size required for assembling the metal to the stud/nut/pin.

2) Parts for Mini Die Tool - the first of which is a nipple that forms the tip of the tool. It can be of various lengths depending upon the depth required of the flangeform application. The second is a spring/washer/clip set. These items are imported together and are sold on a one-to-one ratio to manufacturers.

3) Flangeform Automatic Feed Distributor - is a stand alone machine which is used to feed Flangeform nuts to various types of presses in the electronic, appliance, automotive, and sheet metal industries. The machine incorporates a rotary drum distributor and an air system to "blow" nuts through two flexible plastic feed tubes into a feedhead reservoir. An electronic control, which is linked to nut detection sensors, insures that the nuts are continuously fed and properly inserted into the pre-pierced components to which they will be attached. The unit is capable of feeding up to 60 nuts per minute.

The applicable subheading for the Mini Die Tools and the nipple will be 8207.30.6090, Harmonized Tariff Schedule of the United States (HTS), which provides for interchangeable tools for handtools, whether or not power-operated, or for machine-tools: tools for pressing, stamping or punching, and parts thereof: not suitable for cutting metal, and parts thereof: other. The duty rate will be 3.4% ad valorem.

Consideration was given to classifying these products under subheading 8466.94.8080, HTS, as you have suggested. However, as the items are more specifically described in chapter 82, your suggested subheading is inappropriate.

The applicable subheading for the spring will be 7320.20.5045, Harmonized Tariff Schedule of the United States (HTS), which provides for helical springs of wire having a cross-sectional dimension of 5.1mm or more but less than 12.7mm. The duty rate will be 5% ad valorem.

The applicable subheading for the washer will be 7318.22.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for non-threaded articles: other washer. The duty rate will be free.

The applicable subheading for the clip will be 7318.24.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for non-threaded articles: cotters and cotter pins. The duty rate will be 4.9% ad valorem.

Consideration was given to classifying this product under subheading 7320.90.5060, HTS, as you have suggested. However, noting GRI 1, these items are all provided for in the above cited subheadings.

The applicable subheading for the Flangeform Automatic Feed Distributor will be 8479.89.9598, Harmonized Tariff Schedule of the United States (HTS), which provides for machines and mechanical appliances having individual functions, not specified or included elsewhere. The duty rate will be 3.2% ad valorem.

This ruling is being issued under the provisions of Part 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,

Roger J. Silvestri
Director

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See also:

• Tariff No.: 7318.22.00 - Iron or steel, washers (o/than spring washers and other lock washers)
• Tariff No.: 7318.24.00 - Iron or steel, cotters and cotter pins
• Tariff No.: 7320.20.50 - Iron or steel, helical springs (o/than suitable for motor-vehicle suspension)
• Tariff No.: 7320.90.50 - Iron or steel, springs (o/than leaf springs, helical springs or hairsprings)
• Tariff No.: 8207.30.60 - Interchangeable tools for pressing, stamping or punching, not suitable for cutting metal, and base metal parts thereof
• Tariff No.: 8466.94.80 - Other parts and accessories for machines of heading 8462 or 8463 nesi
• Tariff No.: 8479.89.95 - Machines and mechanical appliances having individual functions, not specified or included elsewhere in chap. 84, nesi