CLA-2-84:OT:RR:NC:1:104

Ms. Kim Witkum
Brooks Life Science
15 Elizabeth Drive
Chelmsford, MA 01824

RE: The tariff classification of an A3 SmaRTStore™ from the United Kingdom

Dear Ms. Witkum:

In your letter dated May 24, 2011 you requested a tariff classification ruling.

The A3 SmaRTStore™ is a small to medium size self-contained automated storage and retrieval system. Due to its multi-format storage design, the SmaRTStore™ is able to hold microtubes, SBS plates or vials or a combination of both within the same unit. The SmaRTStore™ provides storage for up to 360,000 collection samples from the pharmaceutical sector as well as the biotechnology industries, reagent suppliers, universities, contract research organizations and hospitals. The system features a temperature controlled and conditioned environment, with inert nitrogen option available. It is compatible with industry standard labware, easily integrated into LIMS or corporate inventory systems and modular cold room enclosure for future expansion. In addition to space efficient fully automated storage, the standard A3 SmaRTStore™ includes sample tracking and inventory software, robotic cherry picking and flexible refrigeration system options.

Once a remove order has been created, the operator (1) logs on, (2) selects the orders screen and (3) presses the “start” icon for the desired order. The SmaRTStore™ delivers the ordered items to the airlock. When the operator presses the “door open/close” pushbutton, the airlock tray extends. After collecting the ordered items from the airlock tray, the operator pushes the “door open/close” pushbutton a second time. At this point, the SmaRTStore™ retracts the airlock tray.

The A3 SmaRTStore™ consists of several major components such as the airlock which allows operators to load and unload trays with racks or plates without disturbing the controlled environment within the store area. The store robot & tray transfer component moves the dedicated airlock tray and storage trays between the storage racking, airlock, picking station tray set downs and inter-store transfer set downs. The store robot consists of 2 servo controlled axes. The T-bar assembly is mounted onto the moving carriage of the tray transfer which is used to grip the target tray. The picking head transfers plates or racks between trays and transfers tubes or vials between racks and trays. Pneumatically operated grippers are mounted to the base of each vertical axis. The storage racking consists of two opposed banks of shelving separated by an aisle that contains the store robot. The front racking accommodates the picking head and airlock devices with space set aside to allow the installation of an interstore transfer unit. The rear racking accommodates the store robot X-axis beam at the base of the assembly.

The environmental chamber provides a temperature controlled inert environment for item storage. The cooling system control unit controls the internal temperature of the storage chamber to the set value entered into the cooling system controller. Storage chamber temperature can be controlled in the range of +20ºC to -20ºC. The electrical control cabinet (1) provides power for the electrical subsystems used to operate the SmaRTStore™ and (2) houses the servo drives used to control the store robot, the station controller computer and its associated uninterruptible power supply unit, and the transformer for the trace heating systems. The electrical control cabinet is located at the rear left hand corner of the SmaRTStore™. The SmaRTStore™ also uses pneumatic services to power a number of actuators on the picking head and airlock sub assemblies. This system is designed to operate with either nitrogen or compressed air. The gas must be dried to an equivalent dew point of air at -20ºC. There is a single feed pipe connected to the SmaRTStore™ pneumatic services plate located behind the smaller of the two stainless steel front doors. The pneumatic services plate divides the incoming gas feed into three separate supplies for the pneumatic actuators, the main chamber purge system and the airlock purge system.

The environmental control utilizes nitrogen to control the oxygen level within the main storage chamber. Nitrogen can also be fed into the airlock chamber to minimize the transfer of contaminants between the laboratory environment and the storage component. The critical display unit provides numerical indication of storage chamber temperature, oxygen level and relative humidity. There are three LED indicators which provide information such as busy, ready and fault status for the SmaRTStore™ system. The environmental information displayed on the critical display unit is resultant from the oxygen and temperature/humidity sensors output signals. The display of such information is not dependent on the SmaRTStore™ station controller. The touchscreen user interface, located at the front of the SmaRTStore™ above the airlock, acts as the control point for the system operator. The touchscreen also provides access to other advanced applications such as the Station Controller, Store Administrator and Alarm Server.

The applicable subheading for the A3 SmaRTStore™ will be 8479.89.9899, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Machines and mechanical appliances having individual functions, not specified or included elsewhere in this chapter, parts thereof: Other machines and mechanical appliances: Other: Other: Other. The rate of duty will be 2.5% ad valorem.

Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.

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 Patricia O’Donnell at (646) 733-3011.

Sincerely,

Robert B. Swierupski
Director
National Commodity Specialist Division