CLA-2-:OT:RR:NC:N1:405
Ms. Theresa Lynn Bennett
John S. James Company
2702 Azalea Drive
Charleston, SC 29405
RE: The tariff classification of an Asphalt Binder Cracking Device system
Dear Ms. Bennett:
In your letter dated March 7, 2014, you requested a tariff classification ruling on behalf of EZ Asphalt Technology, LLC for an Asphalt Binder Cracking Device system, which you plan to export to various countries including Russia, Poland and China.
The Asphalt Binder Cracking Device (ABCD) system is an instrument used to determine the cracking temperature of asphalt binders. During a test, liquid binder is heated and poured into the ABCD and placed in the cooling chamber where the temperature in the chamber drops over a period of a few hours. As it cools, the binder becomes more and more solid and eventually cracks. The device has an electrical strain gauge and a temperature sensor (RTD type) permanently glued inside each ABD ring to determine when and at what temperature the cracking occurs. The cooling chamber can cool a sample to -60 degrees Celsius.
The system will be disassembled for transport but you state that the entire disassembled system will be exported in a single shipment. The disassembled system includes the environmental chamber, the computer and acquisition system, the specimen silicone molds, the ABCD rings and the testing accessories consisting of the temperature controlled pouring device and turntables. Because the shipment will contain all the parts of the disassembled ABCD system, it will be classified as one complete system.
The applicable subheading for the ABCD system will be 9024.80.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for machines and appliances for testing the hardness, strength, compressibility, elasticity or other mechanical properties of materials other than metals.
You also requested information regarding other governmental agency requirements for importing or exporting these products. Please check with the U.S. Department of Commerce Bureau of Industry and Security for information on possible restrictions or other requirements. Their website is http://www.bis.doc.gov.
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 Barbara Kiefer at [email protected].
Sincerely,
Gwenn Klein Kirschner
Acting Director
National Commodity Specialist Division