CLA-2-87:OT:RR:NC:N1:106

Mr. Michael Roll
Pisani & Roll
1875 Century Park East
Los Angeles, CA 90067

RE: The tariff classification of hand-operated die-cutting and embossing machines and dies

Dear Mr. Roll,

In your letter dated October 29, 2007, you requested a tariff classification ruling on behalf of your client Ellison Educational Equipment, Inc. of Lake Forest, California.

The items concerned are two (2) hand-operated die-cutting and embossing machines, which you have identified in your Ruling Request as the Prestige Space Saver (Part # 19356) and Prestige Select (Part # 19528). The Ellison Prestige line of hand-operated die-cutting and embossing machines are intended for cutting and embossing a variety of materials, but principally paper goods, and are widely used by home hobbyists, students and designers in light-industrial applications. In operation, a die is placed on a traveling platform and manually fed into the area directly under a metal platen that is parallel to the platform. The user applies downward force on a hand-operated lever which lowers the platen onto the die and the material to be cut/embossed to effect the cut or embossed outcome on the material.

You also inquire about the classification of a representative die used in the subject machines. Ellison imports over 10,000 different dies and offers them under a number of brand names. The die in question has been identified as Clear Crop Maple Leaf (Part # 13805). All dies are said to be steel rule cutting dies.

The applicable subheading for the Prestige Space Saver (Part # 19356) and Prestige Select (Part # 19528) cutting/embossing machines will be 8441.10.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other machines for making up paper pulp, paper or paperboard, including cutting machines of all kinds. The general rate of duty will be free.

The applicable subheading for the Clear Crop Maple Leaf (Part # 13805) die for the Prestige cutting/embossing machines will be 8441.90.0000, HTSUS, which provides for parts for other machines for making up paper pulp, paper or paperboard, including cutting machines of all kinds, cutting machines. The general rate of duty will be free.

Duty rates are provided for your convenience and are subject to change. The text of the most recent Harmonized Tariff Schedule of the United States and the accompanying duty rates are provided on the World Wide Web at http://ww.usitc.gov /tata/hts/.

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 Mark Palesek at 646-733-3013.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division