Feb. 11, 1991
Mr. Scott A. Cohn
Grunfeld, Desiderio, Lebowitz & Silverman
12 East 49th Street
New York, N.Y. 10017
RE: The tariff classification of armature and stator
manufacturing machines from Italy
Dear Mr. Cohn:
In your letter dated January 21, 1991 on behalf of Axis USA,
Inc. you requested a tariff classification ruling.
This request represents one of several ruling requests you
have submitted covering the importation of various machines for
the manufacture of armatures and stators. The armatures and
stators made by this equipment will be used as components of
electric motors for small household appliances, power tools, and
automobile DC motors.
Armatures basically consist of coils of wire wound around an
iron core. They are produced by assembling metal laminations, or
stacks, into a cylindrical shape and then inserting a shaft into
slots in the stacks. A commutator, consisting of a molded
plastic ring surrounded by a copper shell, is then placed onto
the end of the shaft, and wires are wound around the shaft and
fused to the commutator. During this process insulating
materials are inserted at various stages so as to protect the
armature components and wires, and the wires are coated with a
resin to protect them from dirt and wear. Finally, the
electrical connections in each completed armature are tested.
The armatures are transported on metal pallets along a conveyor
system from machine to machine as the assembly process occurs.
Stators, which are stationary parts of a motor about which a
rotor revolves, are produced in much the same fashion.
You inquired about the following specific machines:
1. Model ACF commutator fuser - a machine which fuses the
copper wire to the commutator tangs by means of a low voltage
welding head. The welding head heats the tang, causing the
insulation around the wire to melt and fuse to the tang.
2. Model AMTI automatic trickle impregnating machine - a
machine which heats the armatures in a convection oven, trickles
polyester resin onto the exposed copper wires, and then places
the armatures in a second convection oven to gelify and cure the
3. Models SST/W and Sassi GE-SS stator stacking and welding
machines - machines which assemble a stack from pre-formed metal
plates or laminations and then perform a TIG welding operation to
weld the stack together.
4. Model TCM terminal crimping machine - a machine which
mechanically crimps electrical terminals to the stator's wires.
5. Model TFM terminal fusing machine - a machine which
fuses the electrical terminals to the stator wires by means of a
low voltage welding head. The welding head heats the terminals,
causing the insulation around the wires to melt and fuse to the
Control panels for each machine described above may also be
imported with the particular machine.
The applicable subheading for the Model ACF commutator
fuser, Models SST/W and Sassi GE-SS stator stacking and welding
machines, and Model TFM terminal fusing machine will be
8515.21.0000, Harmonized Tariff Schedule of the United States
(HTS), which provides for machines and apparatus for electric
resistance welding of metal: fully or partly automatic. The rate
of duty will be 2 percent ad valorem.
The applicable subheading for the Model AMTI automatic
trickle impregnating machine will be 8514.10.0000, HTS, which
provides for industrial or laboratory electric resistance heated
furnaces and ovens. The rate of duty will be 2.5 percent ad
Finally, the applicable subheading for the Model TCM
terminal crimping machine will be 8479.89.9090, HTS, which
provides for other machines and mechanical appliances having
individual functions, not specified or included elsewhere: other.
The rate of duty will be 3.7 percent ad valorem.
A control panel imported together with the machine it will
control will be classified in the same subheading as the machine.
The above merchandise is not subject to any Voluntary Restraint
Agreements or visa requirements.
In a supplemental letter dated January 31, 1991 you also
inquired about disassembled machines and parts. In the absence
of specific information, we are unable to provide you with a
ruling on these matters. However, for your information, a
particular heading for a machine includes such a machine in a
disassembled state, per General Rule of Interpretation 2(a). If
the importation does not contain all the components of the
disassembled machine, it will still be classified in the heading
for the complete machine provided it has the essential character
of the complete machine. Parts of machines, including spare
parts, which are not goods provided for in any of the other
headings of chapters 84 or 85, nor excluded from chapters 84 or
85, will be classified in the same heading as the machine of
which they are a part provided they are solely or principally
used with such machine (see Notes 1 and 2 of section XVI, Note 1
to chapter 84, and Note 1 of chapter 85, HTS).
This ruling is being issued under the provisions of Section
177 of the Customs Regulations (19 C.F.R. 177).
A copy of this ruling letter should be attached to the entry
documents filed at the time this merchandise is imported. If the
documents have been filed without a copy, this ruling should be
brought to the attention of the Customs officer handling the
Jean F. Maguire
New York Seaport