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March 31, 1999

CLA-2-84:RR:NC:1:103 D89006

CATEGORY: CLASSIFICATION

TARIFF NO.: 8428.90.0010

Mr. Curtis Ikehara
Mechanical Engineering Department
University of Hawaii at Manoa
2450 Dole Street, Holmes 300
Honolulu, Hawaii 96822

RE: The tariff classification of a robotic manipulator arm from Italy

Dear Mr. Ikehara:

In your letter dated February 26, 1999 you requested a tariff classification ruling.

With your inquiry you submitted technical specifications for the MARIS 7080 underwater robotic manipulator arm, as well as information describing the research which will be performed with this device. The MARIS 7080 is an electromechanical manipulator with seven degrees of freedom which is designed to operate at depths up to 6000 meters. It utilizes a pressure compensated housing with an internal or external oil compensation system to withstand the pressure generated at such extreme depths. Each axis of motion is powered by a brushless electric motor keyed to a reduction unit by means of a spur gear. The manipulator also incorporates a gripper capable of exerting a force greater than 200 Newtons, various thermal and displacement sensors, an electronic motor controller assembly, and a connector on which a camera may be mounted (we understand the camera will not be imported with the arm). The metal body of the manipulator contains an anodizing treatment to protect it against corrosion. The unit weighs 55 kilograms, and when fully extended is approximately 1400 millimeters in length.

The MARIS 7080 will be used by faculty, staff, and students at your institution to conduct research on the dynamic interaction of a manipulator and its underwater vehicle, kinematic redundancies between the manipulator and vehicle, and stability of the manipulator when it contacts an external constraint. This research is intended to assist in the development of a novel underwater manipulator and its controller, and in the integration of such a device with a unique Semi-Autonomous Underwater Vehicle for Intervention Missions (SAUVIM) under development for educational and scientific pursuits.

The applicable subheading for the MARIS 7080 underwater robotic manipulator 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 free.

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 Alan Horowitz at 212-637-7027.

Sincerely,

Robert B. Swierupski
Director,

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