CLA-2 CO:R:C:G 087699 JMH

District Director
U.S. Customs Service
Suite 200
Patrick V. McNamara Building
477 Michigan Ave.
Detroit, MI 48266

RE: Protest and Request for Further Review No. 3801-90-000031; tool presetters with optical element used to measure and check the lengths and diameters of the tool and toolholder on various machine tools; measuring and checking appliances and apparatus; optical instruments and apparatus; optical elements; Chapter 90, Additional U.S. Note 3.

Dear Sir:

The following is our decision regarding the Protest and Request for Further Review No. 3801-90-000031, dated January 5, 1990. At issue is the classification under the Harmonized Tariff Schedule of the United States Annotated ("HTSUSA") of certain tool preset machines imported from the Federal Republic of Germany.

FACTS:

The articles in question are tool preset machines manufactured by Gildenmeister-De Vleig in the Federal Republic of Germany and imported by Universal Microbore of Frankenmuth, Michigan. The machines measure and check the lengths and diameters of tools and tool holders to accurately preset the tools of boring machines, milling machines and other machine tools. A comparison of the measurement of the tool and its holder is checked against a zero reference position.

Featured on the tool preset machines are precision glass measuring scales that utilize a photosensitive reading head for determining a tool's length and diameter/radius. An optical profile projector allows optical viewing of the tool and may magnify the tool up to 20 times its actual size. Additionally, each machine includes a precision spindle and a .0001-inch -2-

resolution, two-axis digital readout for displaying and storing up to 40 selectable tool dimensions. The machines are equipped with electrical slide clamps that allow the preset operator to maintain a position, or to clamp the length axis when traversing the diameter axis (or visa versa). The measurements are displayed on a two-axis digital readout. The operator is able to adjust to a general length and diameter and then use the photosensitive reading head and magnification to fine adjust the axes to the tool point.

Upon entry, your port classified the tool presetters in subheading 9031.40.00, HTSUSA, as "Measuring or checking instruments, appliances and machines not specified or included elsewhere in this chapter...Other optical instruments and appliances..." The importer believes that the tool presetters are properly classified in subheading 9031.80.00, HTSUSA, as "Measuring or checking instruments, appliances and machines not specified or included elsewhere in this chapter...Other instruments, appliances and machines..."

ISSUE:

Whether the tool preset machines are "optical instruments and appliances" in subheading 9031.40.00 or "other instruments, appliances and machines" in subheading 9031.80.00.

LAW AND ANALYSIS:

The classification of merchandise under the HTSUSA is governed by the General Rules of Interpretation (GRI's). GRI 1, HTSUSA, states in part that "for legal purposes, classification shall be determined according to the terms of the headings and any relative section or chapter notes and...according ..to the following provisions."

Neither the importer nor your office dispute that heading 9031, HTSUSA, is the appropriate heading in this instance. Heading 9031 describes "Measuring or checking instruments, appliances and machines not specified or included elsewhere in this chapter..." The tool preset machines measure and check the lengths and diameters of tool and tool holders. Thus, the sole dispute concerns the appropriate subheading for the tool preset machines.

GRI 6, HTSUSA, one of "the following provisions" mentioned in GRI 1, requires that the GRI's be employed for the determination of the subheading as they are for the determination of the heading. Thus, the terms of the subheadings and the section and chapter notes must again be examined.

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Chapter 90, Additional U.S. Note 3, HTSUSA, states "the terms "optical appliances" and "optical instruments" refer only to those appliances and instruments which incorporate one or more optical elements, but do not include any appliances or instruments in which the incorporated optical element or elements are solely for viewing a scale or for some other subsidiary purpose." (emphasis added) Thus, if the optical element in the tool presetters is used for a subsidiary purpose to the function of the machine, then the tool presetters are not considered optical appliances or instruments.

The subject tool presetters contain an optical element, the profile projector. The profile projector is necessary for the measuring, checking, and inspection functions of the tool presetter. The digital display of the X-Y coordinates occurs only after the presetter operator has viewed the magnification of the tool through the projector. The projector is a dominant feature to the tool presetter machine. The projector's function is essential, not subsidiary, to the function of the tool presetter.

Since the optical element in question has an essential purpose to the function of the machine, the tool preset machine is considered to be an optical appliance or instrument. The proper classification of the tool preset machines is subheading 9031.40.00 in accordance with GRI 6 and GRI 1.

HOLDING:

The tool preset machines imported from the Federal Republic of Germany incorporate a profile projector. This projector is an optical element that has an essential purpose to the function of the machines. The proper classification of the tool preset machines is in subheading 9031.40.00, as "Measuring or checking instruments, appliances and machines not specified or included elsewhere in this chapter...Other optical instruments and appliances...", in accordance with GRI 6 and GRI 1.

The protest should be denied in full. A copy of this decision should be attached to the Form 19 Notice of Action for the protest.

Sincerely,

John Durant, Director
Commercial Rulings Division