CLA-2-90:S:N:N1:114 849480
Mr. John Douglas, Marketing Manager
Industrial & Research Measurement Systems, Inc.
(I.R.M.)
Carnegie Office Park
Building 1, Suite 230
600 North Bell Avenue
Carnegie, Pennsylvania 15106
RE: The tariff classification of the I.R.M. ROMETER hot-strip
flatness gage from Belgium.
Dear Mr. Douglas:
In your letter dated February 2, 1990, you requested a tariff
classification ruling.
The product for which you request a classification is the I.R.M.
ROMETER--a laser-based flatness gage for measuring on-line flatness
defects in hot strips. These gages are for use by hot strip mills to
accurately measure on-line flatness of steel strips to an
internationally accepted threshold. Among the major industries
utilizing steel strips is the automotive industry.
The applicable subheading for the I.R.M. ROMETER flatness gage
will be 9031.40.0080, Harmonized Tariff Schedule of the United States
(HTS), which provides for other optical measuring or checking
instruments and appliances. The rate of duty will be 10 percent ad
valorem.
This ruling is being issued under the provisions of Section 177
of the Customs Regulations (19 C.F.R. 177).
You indicate in your letter that the I.R.M. ROMETER flatness gage
is priced at $668,493, of which $68,000 consists of U.S.-made parts.
These parts include the following: lasers; power supply; CRT unit;
color printer; electronic board chips; and CCD cameras. Your letter
gives no details as to the assembly operation involved when these
parts are shipped from the United States to Belgium. Therefore, we
are unable to advise you as to the applicability of Subheading
9802.00.8050, HTS, which is detailed in the next paragraph. Subheading 9802.00.8050, HTS, applies to articles assembled
abroad in whole or in part of fabricated components, the products of
the United States, with no operations performed thereon except the
attachment of the components to form the imported merchandise and
operations incidental thereto. An article classified under Subheading
9802.00.8050, HTS, is subject to duty upon the full appraised value of
the imported article, less the cost or value of such products of the
United States.
A copy of this ruling letter should be attached to the entry
documents filed at the time this merchandise is imported. If the
documents have been filed without a copy, this ruling should be
brought to the attention of the Customs officer handling the
transaction.
Sincerely,
Jean F. Maguire
Area Director
New York Seaport