CLA-2-84:OT:RR:NC:N1:104
Mr. Jean-Claude Excoffier
HP Inc.
150 Route du Nant d’Avril
Meyrin
Switzerland
CH1217
RE: The tariff classification of 3D Printer Modules from Singapore
Dear Mr. Excoffier:
In your letter dated December 21, 2017, you requested a tariff classification ruling.
The HP Jet Fusion 3D Printing Solution is a complete system that produces 3D objects using cartridges containing plastic powder materials and fluids. The three separate modules that comprise the HP Jet Fusion 3D Printing Solution are: (1) the HP Jet Fusion 3D Printer (“3D Printer”), (2) the HP Jet Fusion 3D Processing Station (“Processing Station”) and (3) the HP Jet Fusion 3D Build Unit (“Build Unit”). The modules work together to produce 3D objects using HP Multi Jet Fusion Technology.
In Ruling Letter NY N291246 dated November 17, 2017, we provided you with the tariff classification of the HP Jet Fusion 3D Printing Solution when imported complete in one shipment. In your current letter, you request a tariff classification ruling on the three modules when imported separately.
Merchandise is classifiable under the Harmonized Tariff Schedule of the United States (HTSUS) in accordance with the General Rules of Interpretation (GRIs). GRI 1 states in part that for legal purposes, classification shall be determined according to the terms of the headings and any relative section or chapter notes. GRI 2(a) extends the scope of the HTS headings by stating that “Any reference in a heading to an article shall be taken to include a reference to that article incomplete or unfinished, provided that, as entered, the incomplete or unfinished article has the essential character of the complete or finished article. It shall also include a reference to that article complete or finished (or failing to be classified as complete or finished by virtue of this rule), entered unassembled or disassembled.” Under GRI 2(a), the factor or factors which determine essential character will vary with the merchandise. It may, for example, be determined by the nature of a component or components, their bulk, quantity, weight or value, or the role of a component or components in relation to the use of the good. While the build platform is incorporated in the Build Unit, the incomplete 3D Printer does possess key features such as the printheads, the fusing heads and the heating lamps. In this instance, this office finds that the incomplete HP Jet Fusion 3D Printer does have the essential character of a complete 3D printer.
The Processing Station and the Build Unit are said to be (1) designed specifically for the 3D Printer and (2) are essential for the functioning of the 3D Printer.
The Processing Station is said to perform the following operations: (1) controls the cooling time of the Build Unit once the object is printed, (2) helps in the unpacking of the object from the powder bed, (3) sieves powder to eliminate impurities, (4) mixes powders and (5) loads the mix into the Build Unit so as to prepare it for a new job. The Build Unit is said to perform the following operations: (1) carries powder to the 3D Printer, (2) returns with the 3D object in a solid block and (3) moves on for cooling right after job completion which allows for a continuous printing process. As mentioned above, the build platform is located within the Build Unit.
The Build Unit is used in both the 3D Printer and the Processing Station during the 3D Printing process. The Build Unit is first inserted into the Processing Station where the Processing Station loads the supply container of the Build Unit with materials for the additive manufacturing job. Once the loading is complete, the Build Unit is extracted from the Processing Station and moved to the 3D Printer.
Once the Build Unit is inside the 3D Printer, the 3D Printer starts the production of selected job. Upon completion of the 3D object, the Build Unit is removed from the 3D Printer and inserted into the Processing Station for cooling and unpacking operations. All reclaimed material is stored in the storage tank until it is full at which point the reclaimed material is stored in the external tank. The Processing Station’s mixer is fed with fresh material from the material cartridge and reclaimed material from the storage tank. An external tank is provided with the Processing Station for all HP Jet Fusion 3D Printers except for the HP Jet Fusion 3D 3200. It is an optional accessory for the HP Jet Fusion 3D 3200.
In accordance with GRI 2(a), the applicable subheading for the HP Jet Fusion 3D Printer, when separately imported, will be 8477.80.0000, HTSUS, which provides for “Machinery for working rubber or plastics or for the manufacture of products from these materials, not specified or included elsewhere in this chapter; parts thereof: Other machinery”. The rate of duty will be 3.1 percent ad valorem.
In accordance with Note 2(b) to Section XVI, the applicable subheading for the HP Jet Fusion 3D Processing Station and the HP Jet Fusion 3D Build Unit, when separately imported, will be 8477.90.8595, HTSUS, which provides for “Machinery for working rubber or plastics or for the manufacture of products from these materials, not specified or included elsewhere in this chapter; parts thereof: Parts: Other … Other”. The rate of duty will be 3.1 percent ad valorem.
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 https://hts.usitc.gov/current.
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 [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division