CLA-2-84:RR:NC:1:103 K82874

Mr. Joseph R. Hoffacker
Barthco Trade Consultants
7575 Holstein Avenue
Philadelphia, PA 19153

RE: The tariff classification of an insole manufacturing system from Germany

Dear Mr. Hoffacker:

In your letter dated January 27, 2004 on behalf of N.E. Distributors Co. you requested a tariff classification ruling.

The “PED-CAD” Insole Manufacturing System is designed for use by podiatrists or laboratory technicians to make insoles for patients with foot problems. The system is comprised of a scanner, a foot modeler and a milling machine. After the patient’s feet have been scanned and measured, the milling machine mills polyurethane and other plastics to conform to the specific shape of patient’s feet. Precisely measured insoles are created individually for the patient.

The applicable subheading for the “PED-CAD” Insole Manufacturing System, imported in a single shipment and forming a functional unit, will be 8477.80.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for other machinery for working rubber or plastics or for the manufacture of products from these materials. The rate of duty will be 3.1 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 Robert Losche at 646-733-3011.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division