CLA-2-84:RR:NC:1:103 B82646

Mr. Martin W. Bloch
Fritz Companies, Inc.
28265 Beverly Road
Romulus, MI 48174

RE: The tariff classification of P-4 preform manufacturing machinery from Sweden

Dear Mr. Bloch:

In your letter dated February 26, 1997 on behalf of the United States Automotive Materials Partnership you requested a tariff classification ruling.

Information submitted with your inquiry indicates that the imported machinery will be used to assist in the manufacture of large reinforced plastic structural components such as truck bodies. These components can be made rapidly and economically by means of SRIM (structural reaction injection molding) or RTM (resin transfer molding) processes, provided a suitable preform can be produced. The P-4 (Programmable Powdered Preform Process) technology was developed to overcome current limitations in the manufacture of preforms which serve as reinforcements during the component molding process.

The imported machinery will basically consist of a robot with two fiberglass delivery systems, an air ducting and heating system, a mold carrier with preform screens, and a press. The preform screens are perforated and have the same shape as the mold used to produce the final part. The glass fiber delivery system utilizes both a surface veil chopper and a main chopper. The surface veil chopper cuts continuous glass roving into filaments 10 millimeters in length. The main chopper can produce glass fibers varying in length from 15 to 125 millimeters. The computer-controlled robot sprays the glass fiber filaments, which are .001 millimeter in diameter, onto the screen, producing a surface veil so that the preform will not stick to the tool. Simultaneously, air is sucked through the screen to hold the filaments in place. A second layer of chopped or continuous glass fibers, together with a powder binder and a thermoplastic polyester resin filler, is then sprayed onto the screen. These glass fibers can either be randomly distributed or oriented to obtain properties necessary to meet final part performance specifications. Generally, a final surface veil layer of glass fibers is also sprayed over the screen.

The screen then moves into the press, where hot air is forced through the screen for about 20 seconds to melt the binder and filler, and pressure is applied. After undergoing cooling for approximately 5 seconds, the completed preform is ready for demolding. The preform can then be placed into the SRIM or RTM machine and the final component molded.

The applicable subheading for the P-4 preform manufacturing machinery, imported in a single shipment, will be 8477.59.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for machinery for working rubber or plastics or for the manufacture of products from these materials...: other machinery for molding or otherwise forming: other. The rate of duty will be 3.4 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
Chief, Metals & Machinery Branch
National Commodity
Specialist Division