The tariff classification of dispensing and spraying systemsfrom Germany or Mexico

NY 899181 June 24, 1994 CLA-2-84:S:N:N1:106 899181 CATEGORY: Classification TARIFF NO.: 8424.20.1000; 8424.89.0080 Ms. Martha J. Waldner Unitrans International Corporation 709 South Hindry Ave. Inglewood, CA 90301 RE: The tariff classification of dispensing and spraying systems from Germany or Mexico Dear Ms. Waldner: In your letter dated June 9, 1994, on behalf of Calmar, Inc., City of Industry, CA, you requested a tariff classification ruling. You have submitted descriptive brochures depicting the Calmar collection of non-aerosol spraying systems. The imported products are articles used for dispensing and/or spraying various forms of liquids, as follows: The Fine Mist Sprayer (Mark V) is consists of a hood, an orifice cup, a spray head, a piston, a poppet, a shroud, a seal, a valve, a spring, an accumulator, a dip tube, a gasket and a ball. The sprayer has a patented pressure build-up valve which consistently produces a uniform fine mist spray pattern. This feat is accomplished with just 3-1/2 to 4 pounds of finger force. There is no dripping or jetting because of the non-throttling system design. This sprayer has a delivery volume of .14 cc per stroke, and closure sizes are available in 22-415 and 24-410 threaded closures. The Dispenser (MD 3200) consists of a head (Menda), an articulator, a piston, a chaplet, a gasket, a closure (Menda), a spring, a pedestal a valve, an accumulator and an inductor. The sprayer combines the unique concept of the Menda scientific dish- type alcohol dispenser with the reliability and efficiency of the Calmar SSA non-aerosol dispensing system. The MD 3200 system is designed for easy, one-handed delivery of a wide variety of liquids. This dispenser has a delivery volume of approximately .7 cc per stroke. The Trigger Sprayer (TS-800) consists of a nozzle, a discharge valve, a valve body, a shroud, a piston, a trigger, a closure, an inductor retainer, an inductor, a responser, a spherical valve and a gasket. Ten different spray, steam and/or foam nozzle combinations are available to suit the customer's product requirements. Lock-in settings provide positive switching from one position to the next. This sprayer has a delivery of approximately .80 cc per stroke. The TS-800 is designed to fit plastic containers with 28/400 or 28/414 neck finishes. The Dispenser (SD-200) consists of a dispensing head, a chaplet, a 5/32 inch ball valve, a 3/16 inch ball valve, an accumulator, a piston, a dispenser seal, a dip tube, a gasket, a closure, and a spring. The SD-200 was created to provide optimum dispensing capabilities for products requiring an output of approximately 2 ml. This system is used for dispensing liquid soaps, as well as lotions, shampoos, hair conditions, pharmaceuticals, cleansers and household chemicals. The pump head is available with two stock heads (a standard or a highly stylized saddle head design). Screw caps come in 24 mm, 28 mm and 33 mm sizes; and 400, 410 and 415 neck lengths. This dispenser has a delivery of approximately 2 ml. per stroke. The applicable subheading for the Fine Mist Sprayer (Mark V) and Trigger Sprayer (TS-800) will be 8424.20.1000, Harmonized Tariff Schedule of the United States (HTS), which provides for simple piston pump sprays and powder bellows. The general rate of duty will be 5.7 percent ad valorem. The applicable subheading for the Dispenser (MD 3200) and Dispenser (SD-200) will be 8424.89.0080, HTS, which provides for other mechanical appliances (whether or not hand operated) for projecting, dispersing or spraying liquids or powders. The general rate of duty will be 3.7 percent ad valorem. This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177). A copy of this ruling letter should be attached to the entry documents filed at the time this merchandise is imported. If the documents have been filed without a copy, this ruling should be brought to the attention of the Customs officer handling the transaction. Sincerely, Jean F. Maguire Area Director New York Seaport