Mr. Michael J. Skidmore
103 Greenleaf Street
Quincy, MA 02169
RE: The tariff classification of motors and a control board from China or Germany
Dear Mr. Skidmore:
In your letter dated August 13, 2004 on behalf of GSI Lumonics, Inc. of Billerica, Massachusetts you requested a tariff classification ruling.
Your request covers optical scanners and controllers for which you have provided literature, user’s manuals and diagrams. Both the CRS and FM Scanners (FM 2 and FM3) are limited rotational devices for directing light beams and contain shafts upon which typically mirrors are mounted. Without the mirrors they are essentially special types of brushless DC motors. The CRS has a maximum output in watts of 2 watts while the FM2’s maximum output is 20 watts and the FM3 is 25 watts. You state that their limited rotational motion puts them in a subset of electric motors called scanners and/or galvanometers. In your original request of February 5, 2004 you indicated that the scanners would be imported without the optical mirrors. You now indicate that the FM models may be imported with and without the mirror and the CRS will only be imported with the mirror attached.
The FM Scanner Series is used primarily for photo-imaging. These scanners consist of a rotor terminated with a magnet on one side and a configurable mirror on the other side. The rotor is attached to a stator body that creates a magnetic field when current runs through it. This enables the magnet/rotor/mirror assembly to turn. However, instead of operating at the torsional resonance, the FM scanner uses capacitive position feedback to control its motion. The position feedback is created by a dielectric attached to the rotor. As the rotor turns, the dielectric moves between the two capacitive plates. With the dielectric turning, the capacitive changes and causes a linear change in its current output. This current output is then converted to a position feedback signal sent back to the servo controller board.
The MiniSax Controller is only used with the FM Series Scanners. The MiniSax servo board monitors the mirror position feedback signal from the FM scanner. It compares its “command” signal input with the position feedback signal from the scanner. If the position signal does not equal the command signal, the servo will send current to the stator, making the rotor turn until the command equals the feedback position. The command signal can be any type of waveform including step, triangle, raster or sinusoidal waves. Typical command frequencies range from 1 to 300 Hz.
The CRS (Counter Rotating Scanner) Scanner is used in inspection applications in the lumber and automotive industries. It operates with a torsion bar that is terminated on one side with a magnet and with a permanently mounted mirror on the other side. The torsion bar is held at its node (the center point of the torsional twist where no motion occurs) in a stator body. The stator body contains coils that create a magnetic field when current is running through them. The induced magnetic field creates a reactive force on the magnet attached to the rotor assembly causing it to turn, and at the same time exciting the torsion bar’s natural resonance. As the magnet rotates in one direction, the mirror on the other end will rotate with equal motion in the opposite direction. In normal operation an incident light beam on the mirror will be scanned at the frequency of the torsional resonance. This resonance is maintained by the CRS driver board that sends excitation pulses to the scanner every period of its resonance. The CRS scanner will only scan at a single resonant frequency (i.e. sinusoidal motion) as defined by its physical characteristics. The standard frequencies are 4 and 8 kHz.
The applicable subheading for the FM Scanner imported without the mirror will be 8501.10.6040, Harmonized Tariff Schedule of the United States (HTS), which provides for other electric motors, of an output of 18.65 watts or more but not exceeding 37.5 watts: DC: Brushless. The rate of duty will be 2.8 percent ad valorem.
The applicable subheading for the MiniSax Controller board will be 8537.10.9070, HTS, which provides for for other boards, panels, … and other bases, …, for electric control or the distribution of electricity: For a voltage not exceeding 1,000 V. The rate of duty will be 2.7 percent ad valorem.
We are unable to classify the CRS Scanner Series at this time because we require additional information. In your letter of August 13, 2004, you state that, contrary to the earlier letter, the CRS series will only be imported with the mirror attached. You state that the scanner has multiple functions such as inspecting the quality of lumber and inspection in the automobile industry. The GSI Lumonics descriptive brochure pertaining to the CRS Series indicates eight different uses/applications for the CRS Series scanners. There are a total of ten different uses for the CRS scanners.
Please provide an explanation of each of these uses. Specifically, how is the CRS scanner used in each of these applications? Also, what is the approximate percentage of use for each of the ten applications?
We are unable to classify the FM Optical Scanner Series imported with the mirror. Your letter states that the FM scanners are used primarily for photo-imaging. In order to classify the FM Scanner Series with mirror, we need specific information about the photo-imaging application. What devices are the FM Scanners incorporated in? The descriptive brochure states that the FM Scanners are used in print engines. What type of print engine? What is the end product produced by the photo-imaging equipment? Please be specific in your reply.
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 646-733-3011.
Robert B. Swierupski