The tariff classification of a table changing system from Italy

N281437 December 22, 2016 CLA-2-84:OT:RR:NC:N1:104 CATEGORY: Classification TARIFF NO.: 8428.90.0290 Mr. Douglas B. Jauch Salvagnini America 27 Bicentennial Ct. Hamilton, OH 45015 RE: The tariff classification of a table changing system from Italy Dear Mr. Jauch: In your letter dated November 14, 2016 you requested a tariff classification ruling. Your letter states that this request is for a prospective transaction where you are importing the table changing system for a L3 laser cutting machine. Due to its size, it is being imported in two 40’ containers in the same shipment at the same time. The L3’s cutting module, i.e., the laser system, is not included at time of importation.  It is sourced domestically.  The imported table changing system is designed to move and position the material. The two machines that make up a L3 machine are connected to each other by various means such as roller conveyors, metal belt conveyors or suction cup assembly which transfers 1 table to another table via rails. These connection machines are custom designed according to the importer and are shipped in separate containers. The table changing system consists of two metal tables, i.e., an outside table and an inside table that supports the sheet metal that moves in and out of the cutting area. One table is always in the cutting area and the other table is outside being loaded with the sheet metal. The sheet metal is placed on the outside table which then moves up and the inside table comes out. The outside table then moves into the cutting area where the material is checked for its position and the program begins the cutting sequence. The cutting sequence is controlled by a PC and the motors move the cutting head to specific postions on the sheet in order to obtain the programmed part. Again, the table changing system itself performs no cutting. There are no robot grippers used to hold the sheet metal. The weight of the sheet metal itself prevents the sheet from moving during the transfer of the tables and cutting process. The applicable subheading for the handling system, as described above, will be 8428.90.0290, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Other lifting, handling, loading or unloading machinery (for example, elevators, escalators, conveyors, teleferics); Other machinery: 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