The tariff classification of a Plasma Spray Gun from Germany

N277228 August 9, 2016 CLA-2-85:OT:RR:NC:N1:104 CATEGORY: Classification TARIFF NO.: 8515.80.0080 Mr. Christopher Constantine Overlikon Metco US Inc. 1101 Prospect Ave. Westbury, NY 11590 RE: The tariff classification of a Plasma Spray Gun from Germany Dear Mr. Constantine: In your letter dated July 8, 2016 you requested a tariff classification ruling. The SinplexPro Plasma Spray Guns are universal because they can be adapted for use with existing plasma spray systems. They are designed to inject the feedstock material into the hot gas plume where it is melted and then propelled towards the target substrate to form the thermal spray coating. Feedstock material includes pure metals, metallic alloys, oxide ceramics, carbides and cermets. SinplexPro Plasma Spray Guns combine the benefits of a cascading anode design with the simplicity of a single-cathode. The SinplexPro Plasma Spray Guns comes in two models: the SinplexPro-180 which gives a 180? spray angle and a SinplexPro-90 which gives a 90? spray angle. A choice of nozzles and powder ports allows the SinplexPro spray guns to be used in a wide range of plasma spray applications. The SinplexPro spray parameters can use argon, argon-helium or argon-hydrogen as the plasma process gases. The SinplexPro spray guns provide the benefits of using cascaded arc technology, i.e., (1) higher voltage lower amperage operation, (2) a magnitude of reduction in voltage oscillation and (3) the influence of gas flow and type on the arc behavior is eliminated. The cascade fixes the length of the electric arc and provides the arc with a starting path over a series of electrically neutral rings (neutrodes) with the arc chamber. Once the gun is fully ignited only the front anode (nozzle) is electrically connected to the power supply. The applicable subheading for the SinplexPro Plasma Spray Guns will be 8515.80.0080, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Electric (including electrically heated gas), laser or other light or photon beam, ultrasonic, electron beam, magnetic pulse or plasma arc soldering, brazing or welding machines and apparatus, whether or not capable of cutting; electric machines and apparatus for hot spraying of metals or cermets; parts thereof: Other machines and apparatus … Other”. The rate of duty will be free. 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 https://hts.usitc.gov/current. 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 patricia.k.odonnell@cbp.dhs.gov. Sincerely, Steven A. Mack Director National Commodity Specialist Division