CLA-2-82:OT:RR:NC:1:104
Mr. David Peterson
Perfect Point EDM Inc.
15000-C Bolsa Chica Street
Huntington Beach, CA 92649
RE: The tariff classification of PPedm Electrodes
Dear Mr. Peterson:
In your letter dated January 11, 2013 you requested a tariff classification ruling.
The PPedm Electrodes are designed for use only in the Perfect Point™ e-drill which utilizes electro discharge machining (“EDM”) to remove rivets from aircraft. The EDM process weakens the fasteners by electrically eroding a circular groove through the fastener head and a short distance into the stem (or pin) of the aircraft fastener. The depth of cutting is controlled automatically. A thin wall is formed holding the fastener head in place. The fastener head may then be easily severed by a sharp tap of a hammer and a hand punch. The cutting electrodes are consumed during the EDM aircraft fastener cutting process.
In your letter, you state that the PPedm Electrodes do not contain by weight over 0.2 percent of chromium, molybdenum, or tungsten or over 0.1 percent of vanadium. In addition, they are not coated or cored with any flux material. They are available in 18 different sizes and two different materials, 464 Brass Alloy or 145 Copper Alloy. The electrodes are manufactured in a range of sizes to remove various sizes of aircraft fasteners. They are packaged in semi-clear polycarbonate bags in packs of five each.
The applicable subheading for the PPedm Electrodes will be 8207.50.4060, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Interchangeable tools for hand tools, whether or not power operated, or for machine-tools (for example, for pressing, stamping, punching, tapping, threading, drilling, boring, broaching, milling, turning or screwdriving), including dies for drawing or extruding metal, and rock drilling or earth boring tools; base metal parts thereof: Tools for drilling, other than for rock drilling, and parts thereof: Other: Suitable for cutting metal, and parts thereof … Other”.
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,
Thomas J. Russo
Director
National Commodity Specialist Division