Ms. Jacquelyn Votra
Trans-Border Global Freight Services
2103 Route 9
Round Lake, NY 12151

RE: The tariff classification of a Release Coating Line from Germany.

Dear Ms. Votra:

In your letter dated August 19, 2022, you requested a tariff classification ruling on behalf of your client, Felix Schoeller North America Inc.

The “Coater 7” Release Coating Line is an interconnection of machines/apparatuses that performs coating of multiple substrates including paper, photo medical paper, PE-coated paper, PET film, and PE-coated PET film, using solvent-based and solvent-free silicone release agents. A release liner is a paper or plastic-based film sheet that is used to carry and prevent the sticky surface from adhering before its use. Silicone release liner substrates are used in a variety of products such as adhesive tapes and labels. The Line is imported unassembled and will include the full machinery line.

The Release Coating Line utilizes a system of rollers and controlled temperature and humidity changes to produce the finished goods. All machine line apparatuses are connected to a central control system. An unwinder brings the substrate rolls into the machine. Next, a high voltage discharge between an electrode and the substrate increases the substrate’s surface energy, improving the adhesion of the coating onto the substrate. A printing apparatus applies a logo print on the back side of the substrate, while a printing dryer evaporates and dries the printing color. A coating station applies the coating mass onto the substrate using a coating roll. A dryer evaporates and cures the coating mass. Cooling rolls then reduce the coated substrate’s temperature to prevent sticking on subsequent rollers. The substrate’s edges are cut to required width, and humidity is applied to the substrate to prevent waviness. The substrates are then cooled and inspected. Finally, the substrates are rewound.

When imported together in one shipment in accordance with 19 C.F.R. 147.57 and 19 C.F.R. 141.58, the machines or apparatuses comprising the Release Coating Line are intended to contribute together to the clearly defined function of coating multiple substrates and, therefore, form one functional unit. See Note 4 to Section XVI.

In your submission, you requested tariff classification under subheadings 8441.80.0000 or 8439.30.0000, Harmonized Tariff Schedule of the United States (HTSUS). We disagree. Heading 8441 provides for machinery for making up paper pulp, paper, or paperboard after it has been manufactured.  Heading 8439, in pertinent part, describes machinery for making or finishing paper.  The Release Coating Line consists of a line of machines or apparatuses that are used to coat various substrates with silicone, including PET films.  The submitted information does not provide sufficient evidence to establish that the coating line is intended to be used primarily with paper.  Therefore, we find that neither heading 8441 nor heading 8439 are applicable to the imported merchandise.

Heading 8479, HTSUS, and EN 84.79 provide for machines and mechanical appliances having individual functions, not specified, or included elsewhere in Chapter 84, HTSUS. The imported coating line is not described by any other heading in Chapter 84, HTSUS. By operation of Note 4 to Section XVI, HTSUS, the Release Coating Line is imported in one shipment and all its interconnected components contribute together to a clearly defined function. The clearly defined function of this machine is coating of various substrates. U.S. Customs and Border Protection has classified coating lines for various substrates in heading 8479. See, e.g., HQ H251210, dated Apr. 17, 2017 (coating line for coating various substrates with pre-melted adhesive).

The applicable subheading for the Coater 7 Release Coating Line will be 8479.89.9599, HTSUS, which provides for “Machines and mechanical appliances having individual functions, not specified or included elsewhere in this chapter; parts thereof: Other machines and mechanical appliances: Other: Other” at the general, column one rate of duty of 2.5 percent ad valorem. 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 at

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 Arthur Purcell at [email protected].


Steven A. Mack
National Commodity Specialist Division