Feb. 19, 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 articles:
1. Model SBM stator bonding machine - a machine which
utilizes resistance heating from low voltage electrodes to melt
the insulation on copper wires, thus bonding the wires together.
2. Model STS stator testing machine - an electrical probe
which measures resistance in order to test the quality of the
wire bond. It is not equipped with a recording device.
3. Model SBT stator bonder tester - a machine which both
bonds the copper wires by means of resistance heating and
electrically tests the quality of the bond.
Control panels for each machine described above may also be
imported with the particular machine.
The applicable subheading for the Model SBM stator bonding
machine and the Model SBT stator bonder tester will be
8515.21.0000, Harmonized Tariff Schedule of the United States
(HTS), which provides for machines and apparatus for electric
resistance welding of metals: fully or partly automatic. The
rate of duty will be 2 percent ad valorem.
The applicable subheading for the Model STS stator testing
machine will be 9030.39.0040, HTS, which provides for other
instruments and apparatus for measuring or checking voltage,
current resistance or power, without a recording device. The
rate of duty will be 4.9 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 an article includes such an article in a
disassembled state, per General Rule of Interpretation 2(a). If
the importation does not contain all the components of the
disassembled article, it will still be classified in the heading
for the complete article provided it has the essential character
of the complete article. Parts of articles, and spare parts,
which are not goods provided for in any of the other headings of
chapters 84, 85 or 90, nor excluded from chapters 84, 85 or 90,
will be classified in the same heading as the article of which
they are a part provided they are solely or principally used with
such article (see Notes 1 and 2 of section XVI, Note 1 of chapter
84, Note 1 of chapter 85, and Notes 1 and 2 of chapter 90, 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