CLA-2-84:OT:RR:NC:N1:104
Amanda Levitt
Sandler, Travis & Rosenberg, P.A.
675 Third Avenue, Suite 1805-06
New York, NY 10017
RE: The tariff classification of parts of injection-molding machines from China.
Dear Ms. Levitt:
In your letter dated December 17, 2021, you requested a tariff classification ruling on behalf of your client, Husky Injection Molding Systems Ltd., for “cold half” plates of a plastic injection molding machine for the molding of polyethylene terephthalate (PET) articles.
Item No. 8073953, identified as the Core Plate, provides a mounting interface to the moving plate. It spaces and locates cores and cooling tubes, and transfers force. It also provides a network of channels, distributes cooling and air circuits, locates cams, leader pins, OPD brackets, and supports the stripper plate. During operation, this plate remains static relative to the moving platen. The core plate supports the core component of the plastic injection molding machine.
Item No. 8902863, identified as the Cavity Plate, supports the cavity component. The plate locates cavities and gate inserts and aligns with the cores. Further, it aligns with the core plate through leader pin bushings and leader pins. The plate provides and distributes cooling circuits, locates tonnage blocks, transfers tonnage, and lastly, provides a mounting interface to the hot runner.
Item No. 8076295, identified as the Stripper Plate, transfers ejection motion from the machine to the mold. It supports slides and connecting bar assemblies, aligns slide assemblies, and transfers tonnage. It also provides distribution of the stripper plate air circuit and the mounting interface for the wear plates.
Item No. 8129451, identified as the Wear Plates, reduce friction between the slides and stripper plate during ejection stroke. They also support slides in a Z direction and provide distribution of air from the stripper plate. During operation, the wear plates remain static relative to the stationary platen.
Item No. 8098827, identified as the Slides, provide the neck ring interface, and maintain neck ring spacing during the mold opening and ejection stroke. They provide cooling to the neck rings and can withstand dynamic loads generated by cam operation.
You state that the subject items may be imported under two scenarios. In scenario one, each item is imported separately, and in scenario two, the items will be imported together without any other components of the cold half of a PET mold.
For scenarios one and two, the applicable subheading for Item No. 8073953 - Core Plate, Item No. 8902863 - Cavity Plate, Item No. 8076295 - Stripper Plate, Item No. 8129451 - Wear Plates, and Item No. 8098827 - Slides, will be 8477.90.8501, Harmonized Tariff Schedule of the United States (HTSUS), which provides for “Machinery for working rubber or plastics or for the manufacture of products from these materials, not specified or include elsewhere in this chapter; parts thereof: Parts: Other … Of injection-molding machines.” The rate of duty will be 3.1 percent ad valorem.
Products of China classified under subheading 8477.90.8501, HTSUS, unless specifically excluded, are subject to the additional 25 percent ad valorem rate of duty. At the time of importation, you must report the Chapter 99 subheading, i.e., 9903.88.01, in addition to subheading 8477.90.8501, HTSUS, listed above. See U.S. Note 20 to Subchapter III, Chapter 99, HTSUS.
The HTSUS is subject to periodic amendment so you should exercise reasonable care in monitoring the status of goods covered by the Note cited above and the applicable Chapter 99 subheading. For background information regarding the Section 301 trade remedy, you may refer to the relevant parts of the USTR and CBP websites, which are available at https://ustr.gov/issue-areas/enforcement/section-301-investigations/tariff-actions and https://www.cbp.gov/trade/remedies/301-certain-products-china, respectively.
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