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NY C82187





December 29, 1998

CLA-2-85:RR:NC:1: 112 C82187

CATEGORY: CLASSIFICATION

TARIFF NO.: 8543.89.9695; 8543.90.8880; 8208.90.6000

Mr. Leslie Tsuboi
SST International
10415 S. La Cienega Blvd.
P.O. Box 45055
Los Angeles, CA 90045

RE: The tariff classification of thermocutters from Germany

Dear Mr. Tsuboi:

In your letter dated November 19, 1997, on behalf of Abbeon Cal, Inc. you requested a tariff classification ruling.

As indicated by the submitted literature, these thermocutters, identified as models ZETZ-24 and ZETZ-9, are industrial hand held units which use an electrically heated blade designed for cutting all thermoplastics. Model ZETZ-24 is a 500 watt-115 volt unit which consists of a base controller/transformer which is connected to a cutting handle by means of a 9 1/2 foot cable. Model ZETZ-9 is a 120 watt-110 volt unit with the controller/transformer contained in the handle.

The applicable subheading for the model ZETZ-24 and model ZETZ-9 thermocutters will be 8543.89.9695, Harmonized Tariff Schedule of the United States (HTS), which provides for other electrical machines and apparatus, ..., not specified or included elsewhere in Chapter 85, HTS. The rate of duty will be 3.1 percent ad valorem. For merchandise entered for consumption, or withdrawn from warehouse for consumption, on or after January 1, 1998, the rate of duty will be 2.9 percent ad valorem.

Your letter also includes a request for the classification of the principal parts, i.e., the base controller/transformer; the handles; and the cutting blades. The applicable subheading for the handles will be 8543.90.8880, HTS, which provides for other parts for electrical machines and apparatus, ..., not specified or included elsewhere in Chapter 85, HTS. The rate of duty will be 3.1 percent ad valorem (2.9 percent ad valorem in 1998). The applicable subheading for the cutting blades will be 8208.90.6000, HTS, which provides for knives and cutting blades, for machines or mechanical appliances, and base metal parts thereof: Other: Other. The rate of duty will be 1.5 percent ad valorem (0.7 percent ad valorem in 1998).

We are unable to provide a classification for the base unit controller/transformer. Please provide specific information as to the components which comprise the base unit, and explain exactly how it functions, including the individual functions of each component.

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 David Curran at 212-466-5680.

Sincerely,

Robert B. Swierupski
Director,

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