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NY J88813




October 15, 2003

CLA-2-90:RR:NC:MM:114 J88813

CATEGORY: CLASSIFICATION

TARIFF NO.: 9031.49.90

Mr. John F. Norris
W.J. Norris Inc.
80 King Spring Road
P.O. Box 3426
Windsor Locks, CT 06096-3426

RE: The tariff classification of the Trumpf Qualifier 1250 and Trumpf Qualifier 2500 from Germany

Dear Mr. Norris:

In your letter dated September 16, 2003, on behalf of Trumpf Inc., you requested a tariff classification ruling on the Trumpf Qualifier 1250 and Trumpf Qualifier 2500 from Germany. A sales brochure which details the machines description, principle use and technical data was submitted with your ruling request. The submitted brochure states that at high speed and with consistently high precision, the Trumpf Qualifier 1250 and Trumpf Qualifier 2500 perform the quality assurance tasks required by Quality Standard DIN ISO 9001ff. The literature indicates that the basis of the machine frame is formed by a massive granite block that gives the machine its stability and precision. All the workpieces that need measuring are laid on a glass plate that is supported securely by the granite block. It is also possible to scan workpiece areas that project beyond the glass plate. Beneath the glass plate, an illumination unit traverses, and its light is emitted telecentrically, i.e. vertically upward, with parallel beams. Above the glass plate and synchronous with the illumination unit, a CCD camera moves to and fro, creating silhouettes of workpiece sections 50 times per second. Each time, a linear measurement system determines the camera position with a dimensional accuracy of 1 um. Included as standard equipment with the machine is software with a graphic interface that begins by importing the drawings of the workpiece from your CAD system. The software compares the measured actual contour with the CAD drawing. The measuring data is then collected in a report, saved and printed. The machine not only supports you during the actual quality check itself but also with the documentation of the measured results.

The submitted brochure indicates that the method the Trumpf Qualifier 1250 and Trumpf Qualifier 2500 employ is known as laser triangulation. Laser triangulation utilizes a laser diode to guide a laser beam onto various points on the workpiece. Since the laser beam hits the surface at an angle, impact points located high up on the workpiece appear offset to the camera, which is directed down vertically. This offset is used to determine the height of the point, and the method is accurate to within 0.1 mm. The camera and the laser diode can both be moved up and down together, enabling formed components up to 40 mm high to be measured. The applicable subheading for the Trumpf Qualifier 1250 and Trumpf Qualifier 2500 will be 9031.49.90, Harmonized Tariff Schedule of the United States (HTS), which provides for measuring or checking instruments, appliances and machines, not specified or included elsewhere in this chapter; other optical instruments and appliances; other; other. The rate of duty will be 3.5 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 646-733-3019.

Sincerely,

Robert B. Swierupski
Director,

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