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NY C83087





January 13, 1998

CLA-2-90:RR:NC:MM:114 C83087

CATEGORY: CLASSIFICATION

TARIFF NO.: 9031.90.5800

Mr. Steve Sanders
Fritz Companies, Inc.
P.O. Box 1929
#2-12th Street
Blaine, Washington, WA 98231

RE: The tariff classification of positioning system components from Canada

Dear Mr. Sanders:

In your letter dated December 10, 1997, on behalf of Concurrent Mechanical Integration, Inc., you requested a tariff classification ruling.

The mechanical structures for the laser alignment servo positioner unit will be imported from Canada. Laser alignment incorporates laser technology with robotic automated positioning and computer control apparatus to facilitate the alignment of parts of aircraft in order to join them.

The airplane parts are placed on the positioners which are equipped with servo motors. Each positioner is mounted on a base in a vertical or horizontal position. The positioners gather data from sensors and align the airplane parts in the proper position for joining. Optical targets are placed on the airplane parts. The laser scans the targets and reports the data back to the computer control system. The control system computes the required axis moves and orchestrates multiple positioner movements in order to properly align the parts for joining. The laser alignment servo positioners provide in-process measurement data to produce a more accurate assembly than possible with traditional measurement methods.

The mechanical structures for the laser alignment servo positioner unit will be imported. These include the fabricated and machined steel and aluminum parts, bearings, liner bearing assemblies, ball screws, acme screws, proximity switches, gear boxes and cable tracks. The laser units, optical targets and control systems are being supplied by other suppliers in the United States. The positioning system requires data from the laser measuring system in order to operate; the positioning units do not have a function apart from the laser alignment system. Input data is required from the laser system to calculate the positional movements.

The applicable subheading for the mechanical structures for the laser alignment servo positioning units will be 9031.90.5800, Harmonized Tariff Schedule of the United States (HTS), which provides for parts and accessories, of other optical instruments and appliances, other than test benches, other. The rate of duty will be 4.8 percent 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 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 Barbara Kiefer at 212-466-5685.

Sincerely,

Robert B. Swierupski
Director,

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