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NY H86511




December 20, 2001

CLA-2-84:RR:NC:1:103 H86511

CATEGORY: CLASSIFICATION

TARIFF NO.: 8428.90.0010; 8477.80.0000

Mr. Joseph J. Kenny
J.F. Moran Co., Inc.
475 Douglas Pike
Smithfield, RI 02917

RE: The tariff classification of robots from Germany

Dear Mr. Kenny:

In your letter dated December 4, 2001 on behalf of Neureder USA, Inc. you requested a tariff classification ruling.

You submitted brochures describing the CB, CNC, and UP series of industrial robots which your client will import for use with plastic injection molding machines. The robots will be imported with controllers, software, and appropriate end of arm tooling.

The CB and CNC series of cartesian robots are high speed, servo driven, linear removal robots. The CB robots are capable of holding objects weighing from 15 to 55 kilograms, while the CNC series can hold from 15 to 85 kilograms. They feature X, Y, and Z axis steel arms, a rotating wrist, rack and pinion and/or belt drives, and precision gearboxes. They are controlled by a Bosch RHO 3 or RHO 4 controller allowing teach-in or manual entry of motion points, and have a positional repeatability of .02 millimeter. They will be imported with end of arm tooling and software for performing the functions of unloading and handling.

Neureder will also market the UP series of robots. These 6 axis articulating arm robots, made by Motoman, will be configured with tooling and software for performing such functions as parts degating and trimming, assembly, quality control, and packing. UP series robots utilize a single arm capable of holding from 6 to 165 kilograms, and feature AC servo drives which enable a positional repeatability ranging from .08 to .2 millimeter. They are controlled by a Yasnac XRC 32 bit multi-processor controller which includes a hand-held teach pendant.

The applicable subheading for the CB, CNC and UP series of robots, imported together with end of arm tooling, controller and software for unloading and handling operations, 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.

The applicable subheading for the CB, CNC, and UP series of robots, imported together with end of arm tooling, controller, and software for performing the functions of degating or trimming of excess soft, pliable plastic from molded parts will be 8477.80.0000, HTS, which provides for machinery for working rubber or plastics or for the manufacture of products from these materials, not specified or included elsewhere (in chapter 84): other machinery. The rate of duty will be 3.1 percent ad valorem.

Your inquiry does not provide enough information for us to give a classification ruling on these robots performing other functions. Your request for a classification ruling should include detailed information on the end of arm tooling and its method of operation. When this information is available, you may wish to consider resubmission of your request. We are returning any related samples, exhibits, etc. If you decide to resubmit your request, please include all of the material that we have returned to you..

Finally it should be noted that, in accordance with Note 6 to Chapter 85, software imported on the media of heading 8524 is separately classifiable in the appropriate subheading of heading 8524.

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 646-733-3010.

Sincerely,

Robert B. Swierupski
Director,

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