CLA-2-84:RR:NC:1:103 D82888

Mr. Saul L. Sherman
Attorney at Law
PO Box 820
Water Mill, NY 11976

RE: The tariff classification of a calendering line from Italy and Germany

Dear Mr. Sherman:

In your letter dated October 2, 1998 on behalf of IWF, Inc. you requested a tariff classification ruling.

You submitted a schematic drawing of the calendering line as well as a written description of its operation. The calendering line will be used to join together continuous lengths of plastic sheeting and a non-textile backing. The line will basically consist of the calendering machine itself together with machinery to unroll the backing, feed it into the calender, and wind the combined product onto rolls for transfer to subsequent processing equipment. The line will be imported in five separate shipments (whose sequence may vary) as follows:

1. The calender machine, together with two accumulators;

2. Two calender rolls with inner bearing races;

3. Two spare calender rolls with inner bearing races;

4. The winding and unwinding machines, and splicing table;

5. Additional calender components, including a doctor blade, rolls, frames, supports, and holders.

Once in operation, the unwinding machine unrolls and feeds the backing material over a metal splicing table and into the initial accumulator. The non-mechanical splicing table permits the end of one roll to be manually taped to the beginning of the next, or to be repaired in the event of a break. The accumulator, an accordion-like system of rolls, ensures a steady movement of the backing material into the calender in the event of a disruption in the unwinding process. A rope of molten plastic is rolled into a thin plastic film by the calender, which then combines it with the backing by means of the pressure exerted by a pair of heated rollers. The required temperature, as well as the proper tension and alignment of the materials, is maintained during the process, after which the combined material is cooled by passing it around a series of water-cooled rollers (certain thickness gauges and thermal controls necessary for these operations will be purchased domestically and assembled to the calender after importation). The post-production units consist of another accordion-like accumulator system and the winder which winds the material onto rolls and cuts it to start a new roll. The machinery will be manufactured in Italy, while the calender rolls will be made in Germany.

The applicable subheading for the calender machine, imported together with its accumulators as a functional unit, will be 8420.10.9080, Harmonized Tariff Schedule of the United States (HTS), which provides for calendering or other rolling machines: other: other. The duty rate will be 0.7 percent ad valorem. The applicable subheading for the calender rolls, separately imported, will be 8420.91.9000, HTS, which provides for parts of calendering or other rolling machines: cylinders: other. The duty rate will again be 0.7 percent ad valorem.

The applicable subheading for the winder and unwinder machines will be 8479.89.9797, HTS, which provides for machines and mechanical appliances having individual functions, not specified or included elsewhere (in chapter 84): other machines and mechanical appliances: other: other: other: other. The rate of duty will be 2.7 percent ad valorem.

Finally, the applicable subheading for the metal splicing table will be 9403.20.0030, HTS, which provides for other metal furniture: other: other. The duty rate will be 0.8 percent ad valorem.

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 Alan Horowitz at 212-466-5494.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division