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January 12, 1999

CLA-2-85:RR:NC:1:104 D85945

CATEGORY: CLASSIFICATION

TARIFF NO.: 8515.31.0000

Mr. Arjan Braamskamp
Silicon USA Inc.
One Rockefeller Plaza, Suite 1420
New York, NY 10020

RE: The tariff classification of arc welding machinery from the Netherlands

Dear Mr. Braamskamp:

In your letter dated December 4, 1998 you requested a tariff classification ruling.

The computerized semi-automatic drawn arc stud welding machinery is capable of welding aluminum to aluminum, almost any ferrous, nickel or cobalt base alloy stud onto any ferrous base surface or vice versa. In certain cases, special customizing will allow for underwater welding. The welder is used in the construction, refractory, shipbuilding and automotive industries and in a variety of engineering applications. A built-in microcomputer gives precise control of all weld timings. A built-in non-volatile memory allows the storage of up to 40 different stud welding programs and settings. Precise control of the stud position is made possible by the use of a stepper motor and worm drive in the pistol.

All the stud welders in question operate by the drawn arc welding method. Model S-18 is a single gun machine with a stud welding capacity up to 19 mm (3/4"). This compact unit is suitable for use in small fabrication shops. Model CC-1200 is a double gun machine with a stud welding capacity up to 20 mm (0.787"). This unit is suitable for use on sites where two workmen are always required to complete a job. Model CC-1600 is a double gun machine with a stud welding capacity up to 24 mm (0.94"). This unit is suitable for continuous line production or as an attachment to robotic facilities. Model CC-2400 is a double gun machine with a stud welding capacity up to 36 mm (1.42"). This unit is suitable for site work and applications where long cables are required to reach the welding place. Model CC-5000 is a double gun machine for studs up to 50 mm (2"). This unit is suitable for those applications above M44 studs or rapid welding of larger diameter studs.

The applicable subheading for the computerized semi-automatic drawn arc stud welding machinery will be 8515.31.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for Electric (including electrically heated gas), laser or other light or photon beam, ultrasonic, electron beam, magnetic pulse or plasma arc soldering, brazing or welding machines and apparatus, whether or not capable of cutting; electric machines and apparatus for hot spraying of metals or cermets; parts thereof: Machines and apparatus for arc (including plasma arc) welding of metals: Fully or partly automatic. The rate of duty will be 1.6 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 Robert Losche at 212-466-5670. Effective January 28, 1999, the telephone number will be 212-637-7038.

Sincerely,

Robert B. Swierupski
Director,

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