CLA-2-84:OT:RR:NC:1:104

Mr. Mark Matsudaira
All Freight International, Inc.
131 S.W. 156th Street #200
Seattle, WA 98166

RE: The tariff classification of Random Orbital Buffer/Polishers from China

Dear Mr. Matsudaira:

In your letter dated December 18, 2008 and received by this office on February 17, 2009 on behalf of Star Asia, you requested a tariff classification ruling.

The Vaper 6” and 10” Random Orbital Buffer/Polishers, Models 22505 and 22610 respectively, are designed for polishing, buffing and waxing cars, planes, boats and other coated surfaces. The 6” Model 22505 is powered by a 0.4 amp motor with 120 VAC~60 Hz and delivers 3,500 operations per minute (OPM). The 10” Model 22610 is powered by a 0.92 amp motor with 120 VAC~60 Hz and delivers 3,000 OPM. Both models are tools designed to be held in the hand during use and mimic the motion of circular hand polishing. Each model features a foam backing pad and comes packaged for retail sale together with one terrycloth bonnet and one synthetic wool polishing bonnet. The 10” model also features handles.

With your request, you submitted one sample of the 6” Model 22505 and one sample of the 10” Model 22610. As per your request, the samples are being returned to your office.

The applicable subheading for the Vaper 6” and 10” Random Orbital Buffer/Polishers, Models 22505 and 22610, will be 8467.29.0035, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Tools for working in the hand, pneumatic, hydraulic or with self-contained electric or nonelectric motor, and parts thereof: With self-contained electric motor: Other…Grinders, polishers and sanders: Other: Other. The rate of duty will be Free.

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 on World Wide Web at http://www.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 Patricia O’Donnell at (646) 733-3011.

Sincerely,

Robert B. Swierupski
Director
National Commodity Specialist Division