CLA-2-84:RR:NC:1:104 G89751
Mr. Joseph G. Lance
Great Lakes Packing Systems, Inc.
851 Expressway Dr.
Itasca, Illinois 60143-1323
RE: The tariff classification of machinery for the manufacture of “no nail” packaging from Sweden.
Dear Mr. Lance:
In your letter dated March 29, 2001 you requested a tariff classification ruling.
The machines in question are involved in the production of “no nail”, Foldy Pac boxes (collapsible or foldable, no nail, wooden boxes). The machines produce the hardware from metal strip – profile bands, locker plates and clammerbands – and some of the machines press this hardware into the wood to assemble the boxes. In addition to punching, shearing and bending operations, special tooling is used to push through the metal strip so that the metal fractures into roughly v-shaped protrusions which are forced into the wood to secure the bands and plates. This latter operation is described as “punching nails”.
You have provided descriptions of the machines however they do not include specifications or pictures of the machines. A video was also provided however there is no narration to explain what we are seeing.
The Profile Line Machine is designed to manufacture the profile band for the top and bottom of the Foldy Pac box. The metal band is taken from an uncoiler and fed into the line which consists of feeding rollers, one before and one after the forming section where the band is subjected to punching, shearing and bending operations, after which the band is ejected into output baskets. The profile band has the fractured holes with the v-shaped protrusions below the surface on the side that attaches to the top or bottom of the box and rectangular slots punched out of the part that will be folded over the sides of the box and attached to the lockerplates by metal clips. This machine does not press the press the profile band into the plywood.
The Single Lockerplate Line produces the lockerplates from one inch metal coiled strip and presses the plates into the top and bottom of the plywood used to form the sides of the Foldy Pac box. There is a band feeder positioning the band from the decoiler under a tool in the mechanical press. The locker plate is punched (also some bending) and then moved to the right position in the mechanical press where the operator hand feeds the plywood box sides into the machine to press lockerplates into the plywood.
The Single Clammerband Unit consists of a band feeder which positions the band under a tool in the press to punch the band. The clammerband is then moved by the band feeder to the shears where the band is cut to the correct length. This machine by itself does not press the clammerband into the plywood.
The Clammerband Assembly Line consists of four stations and performs two operations on the Foldy Pac box: presses locker plates at the top and bottom of the box and presses clammer band which joins the side of the box.
(1) At the locker plate station, the plates are punched out of a metal band and then pressed into the plywood which has been placed on the input belt by the machine operator. An output belt moves the sheet into the clammerband station.
(2) At the nail band station, the band is taken from the decoiler and fed into the punch which punches nails continuously . The shear cuts the band in correct lengths by counting of nails in the band and after that the band is moved into the clammerband press by compressed air.
(3) At the clammerband station, the plywood sheets are put together by pressing the clammerband to the sheets. The pressing is repeated until all sides are joined together. The station consists of an input belt and the press.
(4) At the folding press station, a second operator folds the box and manually presses the last corner. It consists of an input belt and the folding press.
The applicable subheading for the Profile Line Machine and the Single Clammerband Unit will be 8462.49.0050, Harmonized Tariff Schedule of the United States (HTS), which provides for machine tools for working metal …: punching or notching machines (including presses), including combined punching and shearing machines: other. The rate of duty will be 4.4 percent.
The applicable subheading for the Single Lockerplate Line and the Clammerband Assembly Line will be 8465.94.0045, HTS, which provides for machine tools (including machines for nailing, stapling, glueing or otherwise assembling) for working wood, cork, bone, hard rubber, hard plastics, or similar hard materials: other: bending or assembly machines. The rate of duty will be 2.9 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