CLA-2-84:OT:RR:NC:N1:106

Douglas G. Martin, Entry Specialist
UPS Supply Chain Solutions
2150 Peace Portal Drive
Blaine, WA 98230

RE: The tariff classification of a veneer drying system from China

Dear Mr. Martin:

In your letter dated March 18, 2010 you requested a tariff classification ruling on behalf of your client Raute Canada of New Westminster, British Columbia.

The item under consideration has been identified as a veneer drying system. You state in your request that, due to the size of the system as a whole, it will be shipped in separate containers in quantity to assemble a single unit with no spare parts.

The plywood veneer dryer consists of four main components:

1) In-feed smoke extraction cell. This cell is at the in feed of the dryer and is used to extract vapors but not essential to the drying process itself.

2) Drying Section also referred to a Hot Section. This part actually dries the veneer. It is kept hot (350-400 degrees F) and consists of 24 six foot cells. Each cell contains radiator(s) for steam or oil heating mediums. Each cell also contains a circulation fan and jet boxes for moving the air to the veneer surface and rollers that convey the veneer.

3) Out-feed smoke extraction cell. This cell at the out feed of the dryer is used to extract vapors coming out of the drying section which like the in feed smoke extraction cell not part of the actual drying process.

4) Cooling Section. This cools the veneer after drying it. It is not part of the drying process but is typically used at mills that process veneer into LVL or plywood directly after processing. This consists of 4 six foot cells combined together on site. This section uses a US made fan and electric motor assembly which, you state, will be installed on site.

In addition to these four main structures, there is also a single drive and a tensioning tower that operates the roller system contained in each section. These will be assembled with the dryer unit but will use US made electric drive motors installed on site in the US.

In addition all of the electric fan motors are US made and will be installed on site in the US.

The applicable subheading for the veneer dryer will be 8419.32.1000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Machinery, plant…equipment,…for the treatment of materials by a process involving a change of temperature such as…drying,…other than machinery or plant of a kind used for domestic purposes;…: For wood,…: For wood”. 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 Mark Palasek at (646) 733-3013.

Sincerely,

Robert B. Swierupski
Director
National Commodity Specialist Division