Mr. Lawrence R. Pilon
Hodes & Pilon
33 North Dearborn Street, Suite 2204
Chicago, Illinois 60602-3109
RE: The tariff classification of robots from Germany.
Dear Mr. Pilon:
In your letter dated October 13, 1997 on behalf of Genesis Systems Group of Davenport, Iowa you requested a tariff classification ruling.
You describe the robots as industrial welding robots manufactured by KUKA Roboter GmbH. They include:
MIG Welding Robot Models KR6/1, KR15/1, KR30/1 and KR 30L15/1.
Spot Welding Robots Models KR125/1, KR125L90/1, KR 125L100/1, KR150/1, KR150L120/1, KR150L150/1 and KR200/1.
As confirmed in your followup letter of October 27, 1997, the spot welding robots are resistance welders. The MIG (Metal Inert Gas) welders are for arc welding. The welding heads for these robots will be attached by Genesis Systems after importation. They will be imported without the welding heads themselves but are otherwise said to be dedicated to welding applications.
Although the literature submitted does not identify any feature which dedicates the robot to any welding process, this office has information that robots with a payload of 100 kg or more are of a class or kind principally used for welding. All of the robots identified as MIG welders have payloads less than 100 kg as well as Model KR125L90/1 identified as a spot welder. In addition, this office has different literature on file for the same models at issue here indicating that applications for these robots include coating, pressure joining, riveting, plasma cutting, waterjet cutting, deburring, polishing, grinding, assembly, machine loading, filling, palletizing, handling, order picking, packing, measuring and inspecting in addition to welding. There is no evidence that any one of these applications represents the principal use.
The applicable subheading for Models KR125/1, KR125L100/1, KR150L120/1, KR150/1, KR150L120/1, KR150L150/1 and KR200/1 will be 8515.21.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for machines and apparatus for resistance welding of metal. The rate of duty will be 0.8 percent.
The applicable subheading for Models KR6/1, KR15/1, KR30/1, KR30L15/1 and KR125L90/1 will be 8479.50.0000, HTS, which provides for machines and mechanical appliances having individual functions, not specified or included elsewhere in this chapter; industrial robots, not elsewhere specified or included. The rate of duty will be 3 percent.
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 212-466-5670.
Robert B. Swierupski