CLA-2-84:OT:RR:NC:1:104
Ms. Donna L. Bade
Sandler, Travis & Rosenberg, P.A.
225 W. Washington Street
Suite 1640
Chicago, IL 60606
RE: The tariff classification of a Puck Key from Malaysia
Dear Ms. Bade:
In your letter dated February 8, 2013 on behalf of your client The Gillette Company you requested a tariff classification ruling.
The round Puck Key is a fabricated part of A6 tool steel designed for use only in the manufacture of Gillette razor blades. The Puck Key is used on a Puck Rotate Assembly component which is a part of the Continuous Cartridge Assembly Machine (CCAM). The CCAM has 690 interlinked pucks that run on a figure 8 loop through the machine. Each puck has a mount on top onto which certain items, such as a plastic housing, a hood, a razor component, etc., are added at each of the CCAM’s substations during the processing of the razor blade units. Since the track is moving, the puck cannot stay in the same position at each station. It needs to be rotated for each component to be added. As the puck is being dragged on the track, it needs to be disengaged for it to be rotated. The function of the round Puck Key is to rise, fit into the bottom of the puck and then rotate the puck so the next component can be added. The puck key is essential for the component assembly process as the puck moves through all the stations of the CCAM.
In your ruling letter, you suggested that Heading 8431 of the Harmonized Tariff Schedule of the United States be considered as a classification for the Puck Key. The ‘puck key’ is used to raise and rotate one of 670 “pucks” used in the manufacturing of Gillette disposable razor cartridges. Although the puck key is necessary for the system, it is not an actual part of the conveyance or handling system. As such classification in 8431 would be excluded.
The applicable subheading for the Puck Key will be 8479.90.9496, HTSUS, which provides for “Machines and mechanical appliances having individual functions, not specified or included elsewhere in this chapter; parts thereof: Parts: Other: 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,
Thomas J. Russo
Director
National Commodity Specialist Division