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NY R01078




December 22, 2004

CLA-2-84:RR:NC:1:102 R01078

CATEGORY: CLASSIFICATION

TARIFF NO.: 8413.19.0000, 8481.80.9050, 8477.90.8595

Mr. Marek Twarowski
Menlo Worldwide Services
314B Moon Clinton Road
Moon Township, PA 15108

RE: The tariff classification of metering machines, mixing heads, mold carriers and a mold press from Italy

Dear Mr. Twarowski:

In your letter dated November 22, 2004 you requested a tariff classification ruling on behalf of your client Cannon USA. The articles in question are described as metering machines, mold carriers and a mold press used in the production of various molded products. Descriptive literature was submitted.

The metering machines include low pressure units, identified as the “B-System”, which are suited for metering out foam materials used in the molding of articles such as gaskets, and high pressure units, identified as “A-Compact”, which are used to produce a range of polyurethane foams, and the “MultiEasyFroth”, which is designed to introduce a controlled amount of liquid carbon dioxide to an existing polyurethane system. Based on the information made available, the metering units are essentially pumps designed for the volumetric control of the process liquids that they are designed to deliver.

You indicate that the metering units incorporate a mixing head, which is essentially a specialized valve, designed to control the flow and mixture of the materials used to produce the foams. One such mixing head is identified as the “Interwet”, which features a special design co-injection chamber for the wetting of fillers. You also indicate that the mixing heads may be imported separate and apart from the metering units.

The literature submitted indicates that the mold carriers are used for the restraint of polyurethane foaming molds. They hold the mold while the metering machine is delivering the foam and while the foam is curing. The carriers, which may be hydraulic or pneumatic, feature a swing forward top platen to assist the operator when demolding the upper mold half, while tilt forward facilities present the lower mold half within easy reach.

The “multidaylight” press is described as a self-containing press structure incorporating a multiple number of platens. Platen sizes can vary in length and width and different panel thicknesses can be produced. Press opening/closing is accomplished via hydraulics. The press holds the mold carriers.

It appears that a complete polyurethane foam molding system of subheading 8477.59.80, Harmonized Tariff Schedule of the United States (HTSUS) would include the “multidaylight” press and at least one mold carrier, metering machine and mixing head. Ms. Jackie Rose of Cannon USA, Inc. has indicated that Cannon does not import complete systems.

The applicable subheading for the metering units will be 8413.19.0000, HTSUS, which provides for other pumps fitted or designed to be fitted with a measuring device. The rate of duty is free.

The applicable subheading for the “Interwet” and other mixing heads, when presented separately, will be 8481.80.9050, HTSUS, which provides for other taps, cocks, valves and similar appliances. The rate of duty will be 2 percent ad valorem.

The applicable subheading for the mold carriers and the “multidaylight” press will be 8477.90.8595, HTSUS, which provides for parts of machines for working rubber or plastics or for the manufacture of products from these materials, not specified or included elsewhere in this chapter: other: other. The rate of duty will be 3.1 percent.

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 Kenneth T. Brock at 646-733-3009.

Sincerely,

Robert B. Swierupski
Director,

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