The tariff classification of a rope braiding system from Germany

N038003 October 9, 2008 CLA-2-84:OT:RR:E:NC:1:104 CATEGORY: Classification TARIFF NO.: 8479.89.9897 Mr. Michael Gamble Compliance Officer Expeditors International of Washington, Inc. 21318 64th Ave. South Kent, WA 98032 RE: The tariff classification of a rope braiding system from Germany Dear Mr. Gamble: In your letter dated September 10, 2008, on behalf of Samson Rope Technologies, Inc., you requested a tariff classification ruling. The SEh 1/48-432 Braiding System is a processing line for the production of braided rope. The system consists of several sections as follows: 1) Rope Braiding Machine/Model SEh 1/48-432 2) Caterpillar/Model PQC 2100 3) Bobbin Winding Machine, semi-automatic/Model SP 05 PN 4) Take-up stand, self-traversing/Model ATU 4500 The bobbin-winding machine winds yarn material onto braider bobbins that are subsequently placed into the braiding machine. The braiding machine braids the yarn into rope. The rope is pulled through the braiding system by the caterpillar and finally wound onto reels by the take-up. In your letter, you request classifications for the merchandise imported in various configurations, e.g., all in one shipment, each item separately and combinations of items such as the braiding machine and the caterpillar in one shipment. The applicable subheading for the Take-Up stand, self-traversing/Model ATU 4500, when imported separately, will be 8479.89.9897, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Machines and mechanical appliances having individual functions, not specified or included elsewhere in this chapter, parts thereof: Other machines and mechanical appliances: Other: Other: Other. The duty rate will be 2.5 percent ad valorem. Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/. Your inquiry does not provide enough information for us to give a classification ruling on the balance of the items described above. Your request for a classification ruling should include literature and specifications on the SEh 1/48-432, PQC 2100 and SP 05 PN. How is the braiding accomplished, e.g., by stranding, twisting or cabling? How does this braiding machine differ from a twisting-frame of a type used in spinning textiles or a textile braiding loom? Provide a representative sample of the type of rope produced by this system (small length only please). What types of mechanism(s) are employed by the caterpillar to pull the rope through the system? Please label the bobbin winding machine on the drawing. There appear to be two machines located behind the braider. Which is the bobbin winding machine? What is the other machine? What is its function? Is this machine ever entered with the system? How are the bobbins placed in the braiding machine? Are they manually moved from the winder to the braider or is there some type of conveying unit between the two machines? If so, is this conveying unit included when the system is imported? 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. 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 Patricia O’Donnell at (646) 733-3011. Sincerely, Robert B. Swierupski Director National Commodity Specialist Division