CLA-2-84:RR:NC:1:104 F85174
Mr. Dennis Heck
Yamaha Corporation of America
6600 Orangethorpe Avenue
P.O. Box 6600
Buena Park, CA 90622-6600
RE: The tariff classification of scribing machines and machines for punching flexible printed circuit boards from Japan.
Dear Mr. Heck:
In your letter dated April 3, 2000 you requested a tariff classification ruling.
The Yamaha YS2 Dry Type Scriber is a numerically controlled high-speed, precision cutting and dry scribing unit that incorporates a diamond rotary cutter. Workpieces such as ceramic, ferrite, barium titanate and glass printed circuit boards can be scribed. The cutter presses into the workpiece at a set pressure, producing scribing lines.
The numerically controlled punchers include the following models:
NC YFP2 Roll Type Film Puncher
NC YFP3-S Sheet Type Film Puncher
NC YP4/G Grid Puncher
YTP302 & YTP504 Y Trim Puncher
In your followup letter of April 7, you indicate that although these machines can punch film and foil, Yamaha will be importing and marketing these machines for the flexible PCB market only. The YFP 2 and 3S are hole punching machines. The YFP punches holes in roll stock flexible PCB material and the 3S punches holes in sheet stock flexible PCB material. The YTP 302 and 504 machines can punch round and irregular holes in sheet stock flexible PCB material. The YP4/G can produce round or square holes in sheet stock.
You submitted a sample of a flexible PCB with holes punched in a manner similar to the way the YFP and YTP machines operate. (The sample will be returned as requested.) The flexible board consists essentially of flexible copper sheeting and plastic laminate. Unlike the non-flexible boards, the laminate does not comprise the bulk of the material.
You suggest that the punchers are classifiable under HTS 8479.89.9797 which provides for machines and mechanical appliances having individual functions, not specified or included elsewhere in this chapter. Since the punchers are machine tools, heading 8479 cannot apply.
The applicable subheading for the Yamaha YS2 Dry Type Scriber will be 8464.90.9090, Harmonized Tariff Schedule of the United States (HTS), which provides for machine tools for working stone, ceramics, concrete, asbestos-cement or like mineral materials or for cold working glass: other: other. The rate of duty will be 2 percent.
The applicable subheading for the numerically controlled punchers will be 8462.41.0080, HTS, which provides for machine tools for working metal …: punching or notching machines (including presses), including combined punching and shearing machines: numerically controlled. The rate of duty will be 4.4 percent.
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 Robert Losche at 212-637-7038.
Sincerely,
Robert B. Swierupski
Director,
National Commodity
Specialist Division