CLA-2-84:OT:RR:NC:N1:104

Sean K. Dunne
Oregon International Air Freight Co.
2345 Vauxhall Road
Union, NJ 07083

RE: The tariff classification of an E-Coating line from Germany.

Dear Mr. Dunne:

In your letter dated September 30, 2019, you requested a tariff classification ruling on behalf of your client, B + M Surface Systems GmbH.

The B + M Pretreatment and E-Coating line is an industrial process used for applying coatings to metal fabricated products, which is typically used in the automotive industry to coat automobile bodies and parts, tractors, and heavy equipment. A characteristic feature of the process is that colloidal particles suspended in a water medium migrate under the influence of an electric field (electrophoresis) and are deposited onto an electrode. All colloidal particles that can be used to form stable suspensions and that can carry a charge can be used in electrophoretic deposition. The e-coating line consists of several sub-processes: (1) pretreatment; (2) e-coating process; (3) rinsing the undeposited paint by UF rinse and virgin permeate; (4) oven baking that will crosslink the polymer; (5) air cooling zone; (6) waste water management system; (7) conveyor system; (8) osmosis and dosing system; (9) anolyte system and rectifier.

When imported together in one shipment in accordance with 19 CFR 147.57 and 19 CFR 141.58, the machines which comprise this Pretreatment and E-Coating line are intended to contribute together to the clearly defined function of treating metal and, thus, form one functional unit. See Note 3 to Section XVI.

The applicable subheading for the B + M Pretreatment and E-Coating line will be 8479.81.0000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “which provides for Machines and mechanical appliances having individual functions, not specified or included elsewhere in this chapter; parts thereof: Other machines and mechanical appliances: For treating metal, including electric wire coil-winders”. 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 the 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 Denise Hopkins at [email protected].

Sincerely,

Steven A. Mack
Director
National Commodity Specialist Division