CLA-2-84:S:N:N1:105 885988
Mr. Terrence L. Mc Cracken
R.J. Mc Cracken CHB
5345 44th Street, S.E.
Grand Rapids, MI 49512-4001
RE: The tariff classification of heating equipment from
Switzerland
Dear Mr. Mc Cracken:
In your letter dated May 3, 1993 you requested a tariff
classification ruling on behalf of Hill Machinery Company.
You submitted four brochures covering the following four
classes of heat machines: Leister sterile hot air jet; Leister-
Labor "S" for dental technicians and dentists; Leister hand-held
welding tools for welding thermoplastics; and Labor "S" not air
tools for the restorer, conservator, and the laboratory.
The sterile hot air jet, called the Leister Hot Air
Coagulator, is an electrically operated device that blows air
through a heating element to produce a jet of hot air, whose
temperature and volume can be finely adjusted from 200 to 500 C.
and from 3 to 30 liters per minute respectively. This hand held
instrument is used for hemostasis, coagulation and shrinking of
tissue in human and veterinary surgery.
The Labor "S" is shown not only in leaflet 42 directed to
dental technicians and dentists, but also in leaflet 21A on hand
held welding tools and in leaflet 40 on tools for restorers,
conservators and laboratories. It thus appears to be a versatile
tool not principally used in dental work.
The hand-held welding tools shown in the submitted brochure
include: the Leister-Labor "S", the Leister-Diode, and the Leister-
Triac. The Diode and Triac appear to be chiefly used for welding
of thermoplastics such as PVC, polyethylene, polypropylene,
acrylics, and polycarbonate. The most frequently used methods of
hot air welding done with these tools are pendulum welding, speed
welding and mirror welding. The Labor "S", on the other hand,
appears to have a multitude of uses.
The hot air tools for the restorer, conservator, and the
laboratory are the Leister-Labor "S" and the Leister Ghibli. Both
have a variety of uses: the Labor "S" as a Bunsen burner in a lab;
in securing detached paint layers on an oil painting; in removing
paint, glue and putty; and in welding and soldering; the Ghibli:
in undoing old glued repairs on earthenware; removing old paint
from doors, furniture and walls; and welding thermoplastics.
The applicable subheading for the Leister-Diode and Leister-
Triac will be 8515.80.0080, Harmonized Tariff Schedule of the
United States (HTS), which provides for electric (including
electrically heated gas) welding machines and apparatus, whether
or not capable of cutting: other. The duty rate will be 2 percent
ad valorem.
The applicable subheading for the Leister Hot Air Coagulator
will be
9018.90.6000, HTS, which provides for electro-surgical instruments
and appliances . . . and parts and accessories thereof. The duty
rate will be 7.9 percent ad valorem.
The question of classification for the Labor "S" and the
Ghibli is being referred to the Office of Regulations and Rulings,
U.S. Customs Service Headquarters, 1301 Constitution Avenue, N.W.,
Washington D.C. 20229. A ruling will be issued to you from that
office.
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