Mr. Kurt M. Moss
Hankyu Hanshin Express
909 W Irving Park Road
Itasca, IL 60143

RE: The tariff classification of Resistance Welding Guns from Japan

Dear Mr. Moss:

In your letter dated June 9, 2016, on behalf of your client, Obara Corporation, you requested a tariff classification ruling.

You state that you are importing two types of welding guns. One is a portable spot welding gun and the other is a robotic welding gun. The imported welding guns are only capable of resistance welding and not arc welding. Submitted literature indicates that these welding guns work on sheet metal. The components of the spot welding gun and the robotic welding gun consist of the cap electrodes, adapters, copper brass bars, shunts, gun arms, actuators (servo or pneumatic) and the transformer. The robotic welding gun also includes the robot mounting bracket in addition to the listed parts. At time of importation, the welding guns consist of the welder itself, lacking minor equipment to fully function such as the power source, the robot, robot controller, and weld controller which are required for the entire automation system. These components supply power, control the movement of the gun and position the gun in position to weld.

Portable spot welding guns are suspended on a trolley system which has a spring balancer to hold the weight of the gun. The weld gun is moved into position by the assembly line worker. Robotic welding guns are mounted to a robot which moves the weld gun into the correct welding position. The robotic welding gun is attached to the robot at the United States manufacturing facility. There are no feeders used with either welding gun. The heat is produced by the resistance to the flow of an electric current through the work piece.

General Rule of Interpretation 2(a) (“GRI 2(a)”), Harmonized Tariff Schedule of the United States (HTSUS), extends the scope of a heading to include an article, whether assembled or unassembled, that is imported incomplete or unfinished provided the article is found to have the essential character of the complete or unfinished good. Under GRI 2(a), the factor or factors which determine essential character will vary with the merchandise. It may, for example, be determined by the nature of a component or components, their bulk, quantity, weight or value, or the role of a component or components in relation to the use of the good. In this instance, this office finds that the resistance welding guns, imported without components such as the power sources, do have the essential character of complete resistance welding guns.

The applicable subheading for the Resistance Welding Guns will be 8515.21.0000, HTSUS, which provides for “Electric (including electrically heated gas), laser or other light or photon beam, ultrasonic, electron beam, magnetic pulse or plasma arc soldering, brazing or welding machines and apparatus, whether or not capable of cutting, electric machines and apparatus for hot spraying of metals or cermets; parts thereof: Machines and apparatus for resistance welding of metal: Fully or partly automatic”. The rate of duty will be free.

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

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


Steven A. Mack
National Commodity Specialist Division