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NY F89941




August 10, 2000

CLA-2-85:RR:NC:1:104 F89941

CATEGORY: CLASSIFICATION

TARIFF NO.: 8514.10.0000; 8514.90.0000; 8412.29.9075; 8414.80.2075; 8419.89.9040

Ms. Kerryn Miller
Flow International Corporation
23500 64th Avenue
Kent, Washington 98032

RE: The tariff classification of Hot Isostatic Presses (HIP) and separately imported components from Sweden.

Dear Ms. Miller:

In your letter dated July 18, 2000 you requested a tariff classification ruling.

You indicate that Flow International would like a ruling for Hot Isostatic Presses (HIP) imported as a complete system and also a ruling on the 6 major sub-components that will be imported separately as spares. In addition to the descriptions and specifications provided in your letter, a brochure has been submitted.

The Quintus Hot Isostatic Presses feature a high pressure vessel, designed for specific pressures between 10,000 and 40,000 psi, equipped with an internal furnace for the application of high temperature, between 800 C and 2000 C. The pressurizing media is a gas, argon. HIP is primarily used for the densification of metal or ceramic powders into net or near-net shapes, the elimination of defects in metal castings, and the metallurgical bonding of similar or dissimilar materials.

The 6 major components that will be imported as spares include the pressure vessel, the furnace, the pressurization and gas handling system, the cooling system, the power supply and control system and the hydraulic system.

The pressure vessel is a forged steel cylinder, prestressed by high strength steel wire windings so that the vessel is under compressive stresses. The frame consists of two columns and two yokes, also prestressed by high strength wire windings. Two straight wall end closures are held in place by the wire wound frame. Vessel support structure, a frame movement carriage and closure manipulator are also supplied.

The furnace includes heating elements mounted on a support shell which also serves as a heat shield for the pressure vessel. It also includes thermocouples and a base support structure which contains resistance heating elements as well as some fans, valves, or heat transfer devices to assist in cooling the system and load after processing. The furnace surrounds the parts to be processed and is typically removed after each cycle.

The pressurization and gas handling system includes a high pressure intensifier capable of pressurizing the vessel to its maximum operating pressure rating, a vacuum system to evacuate the vessel prior to filling with argon, high pressure valve, fittings and tubing to allow for pressurization and depressurization of the vessel. The gas handling system is activated once the vessel is closed.

The cooling system is a closed loop cooling system designed as two circuits. One circuit is an open loop (external). Water for the open loop is taken from an external water supply and fed through a heat exchanger, The closed loop pumps water from storage tanks through the vessel outer jacket and the other side of the heat exchanger. This system is comprised of the following components: water reservoir, circulation pumps, stand by circulation pump, plate heat exchanger, flow control valves, flow and temperature sensors, and a base frame. The cooling system is to keep the vessel at a safe operating temperature.

The power supply and control system includes the furnace and control transformers, SCR’s, motor starters, programmable logic controller and computer for man-machine interface. The system is used to supply power to the resistance heaters and allow for the automatic operation and temperature control of the HIP.

The hydraulic system includes the hydraulics power unit, and traverse cylinders for the frame and closures. It also includes a “jacking ring” to insure the lower closure is in place before the frame is moved.

Based on HQ ruling 952439 of February 3, 1993, you believe that the complete HIP System is classifiable under HTS subheading 8514.10 as an industrial resistance heated electric furnace and that the pressure vessel and furnace would also be classifiable under 8514.10 if imported separately. In addition to classifying a complete hot isostatic press under 8514.10, ruling 952439 classified a pressure vessel assembly which housed a high temperature resistance furnace under 8514.10. Here you are asking for the classification of the pressure vessel and the furnace imported separately rather than imported together as an assembly.

You also ask whether the other components would be classified under HTS subheading 8514.90 as parts of furnaces since they are specially designed to work with the HIP only. Heading 8514 is included in section XVI of the HTS. Section XVI, note 2(a) indicates that parts which are goods included in any of the headings of chapters 84 and 85 are in all cases to be classified in their respective headings. This note precludes classification of these other components in subheading 8514.90.

The applicable subheading for the complete Hot Isostatic Press and the furnace when separately imported will be 8514.10.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for industrial or laboratory electric furnaces and ovens: resistance heated furnaces and ovens. The duty rate will be free.

The applicable subheading for the pressure vessel when separately imported will be 8514.90.0000, HTS, which provides for parts of industrial or laboratory electric furnaces and ovens. The rate of duty will be free.

The pressurization and gas handling system will be classified under subheading 8414.80.2075, HTS, which provides for air or vacuum pumps, air or other gas compressors and fans; . . . other, except parts: other compressors. The rate of duty will be free.

The applicable subheading for the cooling system will be 8419.89.9040, HTS, which provides for machinery, plant or laboratory equipment, whether or not electrically heated, for the treatment of materials by a process involving a change of temperature such as heating, cooking or cooling, other than machinery or plant of a kind for domestic purposes: other machinery, plant or equipment: other: other: other. The rate of duty will be 4.2 percent.

The hydraulic system will be classified under subheading 8412.29.8075, HTS, which provides for other engines and motors: other hydraulic power engines and motors: other: other. The rate of duty will be free.

Your inquiry does not provide enough information for us to give a classification ruling on power supply and control system which includes the furnace and control transformers, SCR’s, motor starters, programmable logic controller and computer for man-machine interface. Your request for a classification ruling should include the following information:

Regarding the furnace and control transformers: What type of transformer is this, i.e., liquid dielectric or other, please specify. What is the power handling capacity in kilovolt-amperes (kVA)? What is the transformer’s function and how does it function within the power supply and control system?

Regarding the computer for man-made interface: Is it part of the programmable logic controller? What is its function?
How does it interface?
What type of computer is it?

How do all of these components interrelate with each other to form this power supply and control system? In their imported condition, will they be mounted in a common housing or will they be physically separate units connected by electrical cables etc.

When this information is available, you may wish to consider resubmission of your request.

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 212-637-7038.

Sincerely,

Robert B. Swierupski
Director,

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