CLA-2-84:S:N:N1:104 812761

8462.49.0050; 8465.92.0090

Mr. Anthony Kaminski
Combi - Net
5233 Hanover Pike
Manchester, Maryland 21102

RE: The tariff classification of laser dieboard cutters, counter cutters, and steel rule cutting, bending and broaching machines from Germany.

Dear Mr. Kaminski:

In your letter dated July 13, 1995 you requested a tariff classification ruling.

The CNC Laser Cutting Systems are used to cut wooden dies for printers and folding box manufacturers. The PLS System includes the PLS 1600, PLS MF 600, PLS MF 1500 and PLS MF 1500 R. The first three models cut flat-bed dies while the last cuts flat bed and rotary dies. The PTS System is a portal type machine in which the cutting nozzle and the work table are each moved independently of each other. The MTS is a compound table machine in which the table that carries the die board is moved in two axes. The CLS is described as a compact laser cutting machine.

The Counter Cutting System HCC 1600 is a PC-controlled matrix milling machine used to machine Pertinax counter matrices. The machine features a five speed milling head and a graphic display that enables the user to view the contours before they are milled. The PCC 110 CNC Counter Cutting System is used to cut single-up-counters of Pertinax. The machine has 5 routing spindles and also features a diagnostic display.

The Computer-Controlled Cassette Rule-Cutting Machine MCC- CAD is a hydraulically operated machine that can be used to cut (shear) straight steel die maker's rules to length, or as a lipper, notcher or hole punch depending on which tool cassette is inserted. The Rule Bending Machine MCB-CAD is a programmable, hydraulically operated rule bending machine that bends 2-point and 3-point diemaker's rules. Where it is necessary to bend sharp angles, it is recommended that the rules be first broached in the MCR-CAD Rule Broaching Machine. None of these steel rule working machines are CNC.

The applicable subheading for the PLS, PTS, MTS and CLS Laser Cutting Machines will be 8456.10.5000, Harmonized Tariff Schedule of the United States (HTS), which provides for machine tools for working any material by removal of material, operated by laser or other light or photon beam processes: other. The rate of duty will be 2.9 percent.

The applicable subheading for the Counter Cutting Systems, Models HCC 1600 and PCC 110, will be 8465.92.0090, HTS, which provides for machine tools for working wood, cork, bone, hard rubber, hard plastics or similar hard materials: other: planing, milling or molding (by cutting) machines. The rate of duty will be 3 percent.

The MCC-CAD Rule Cutting Machine will be classified under HTS subheading 8462.49.0050, which provides for machine tools for working metal ...: punching or notching machines, including combined punching and shearing machines: other. The rate of duty will be 4.4 percent.

The MCB-CAD Rule Bending Machine will be classified under HTS subheading 8462.29.0050, which provides for machine tools for working metal ...: bending, folding, straightening or flattening machines: other. The rate of duty will be 4.4 percent.

The MCR-CAD Rule Broaching Machine will be classified under HTS subheading 8461.30.8080, which provides for machine tools for broaching metal: other. The rate of duty will be 4.4 percent.

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