CLA-2-84:RR:NC:1:103 E87651

Mr. William A. Sharpe
I.C.S. Customs Service Inc.
812 Thorndale Avenue, Suite B
Bensenville, IL 60106

RE: The tariff classification of robots from Switzerland

Dear Mr. Sharpe:

In your letter dated September 9, 1999 on behalf of Geiger Handling you requested a tariff classification ruling.

With your inquiry you submitted brochures describing six models of robots designed to be mounted on injection molding machines and used to remove parts or sprues from the machines. The robots are pneumatically powered linear units basically consisting of a robot body which moves along X, Y, and Z axis rails and a programmable controller. Some models also include a gripper, while other models offer the gripper as an option. The specific models you inquired about are:

EA-15 SL: used to handle molded parts weighing up to 3.5 kilograms (including the weight of an optional gripper);

EA-Mini 2001 FO: used to remove sprues with a maximum weight of 300 grams (including its standard plastic gripper);

EA-Mini 2001 SL: used to unload sprues and plastic parts with a maximum weight, including its standard plastic gripper, of 2 kilograms;

EA-21: for removal of molded parts up to 10 kilograms in weight utilizing an optional plastic or metal gripper;

LR-16: used to handle articles weighing up to 6 kilograms;

LR-21: similar to the model LR-16, but with a handling capacity of 15 kilograms.

The applicable subheading for these robot models, when consisting of the robot along with its controller and a gripper imported together in a single shipment, will be 8428.90.0010, Harmonized Tariff Schedule of the United States (HTS), which provides for other lifting, handling, loading or unloading machinery: other machinery: other: industrial robots. The rate of duty will be free.

When imported without grippers, the applicable subheading for the robots will be 8479.50.0000, HTS, which provides for machines and mechanical appliances having individual functions, not specified or included elsewhere (in chapter 84): industrial robots, not elsewhere specified or included. The rate of duty will be 2.5 percent ad valorem. The controllers for robots imported without grippers will be separately classifiable in subheading 8537.10.90, HTS which provides for boards, panels, consoles desks, cabinets and other bases, equipped with two or more apparatus of heading 8535 or 8536, for electric control or the distribution of electricity, including those incorporating instruments or apparatus of chapter 90, and numerical control apparatus, other than switching apparatus of heading 8517: for a voltage not exceeding 1,000 V: other. The rate of duty will be 2.7 percent ad valorem. . 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 Alan Horowitz at 212-637-7027.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division