CLA-2-84:OT:RR:NC:N1:164
Jason Ricketts
NNA Inc.
One Nissan Way
Franklin, TN 37067
RE: The tariff classification of a servo tandem press line, base plates, and a front-of-line sound wall from
Japan
Dear Mr. Ricketts:
In your letter dated March 12, 2025, you requested a tariff classification ruling regarding a servo tandem
press line from Japan. In subsequent correspondence, you stated that base plates and a front-of-line sound
wall from Japan would be imported into the United States on separate entries. Technical information was
submitted with your request and in subsequent correspondence.
The first item under consideration is described as a servo tandem press line (Model # H5FTL) used to form
automotive parts from flat sheet metal blanks. The automotive parts include, but are not limited to, body,
hood, and door panels. As described, the press line comprises six interconnected component groups: 1)
2400-ton H4FL press with die cushion, 2) 1200-ton H4FL press, 3) three 1000-ton H4FL presses, 4)
front-of-line blank destack equipment (with optional washer and oiler machines, if equipped), 5) product
feeder equipment, and 6) the press line perimeter sound wall. In your letter, you clarify that the
product-specific tooling (upper and lower dies) is supplied separately by your customer and not included with
the servo press line.
Beginning at the front-of-line area, operators load stacks of blank workpieces into loading areas. Next, a
gantry equipped with selectable vacuum cups moves the workpiece onto a conveyor and it travels to optional
washer and oiler machines or a bypass conveyor. At that point, the workpieces are scanned by a camera for
positioning and centered by robots to a desired position. Once positioned, the first feeder moves the
workpiece to the first servo press. During operation, the workpiece is pressed by five servo presses,
successively. In addition to the first feeder, there are four feeders responsible for transferring the workpiece
from one press to the next and one feeder for exit to an exit conveyor (not included). Although the
product-specific shaping of the workpiece is determined by the shape of the dies and not the press line
equipment itself, the movements of the workpiece through the press line, the actions of the feeders, and the
motions performed by each servo press are coordinated and controlled by a central computer unit.
Each of the five servo presses is composed of a crown, connecting rods, slide, slide plate, bolster plate,
bolster, and bed. The crown sits at the top of the press and contains the main servo motors, external
gears/reducers, internal drive gears, and connecting rods of the servo drive system. The connecting rods run
vertically to the slide below. The slide and slide plate hold the upper die. The bed sits at the bottom of the
press and supports the bolster, bolster plate, and lower die. Based on a predetermined motion program, the
servo drive system moves the slide vertically into the workpiece with great force. The pressures exerted on
the workpiece from the slide above and the supporting bolster below shape the workpiece as determined by
the upper and lower dies.
The next items under consideration are described as base plates which anchor the press line to the concrete
footing below. Composed of low-carbon structural steel (SS400), the base plates are custom-machined and
installed to specifications using included anchoring bolts. In addition, the base plates feature three adjustable
bolts to enhance the accuracy of the press line by ensuring a level surface with ample support during
operation. You state that the base plates are specialized to fit the servo tandem press line and cannot be used
interchangeably in another application.
The final item under consideration is described as the front-of-line sound wall which provides a common
housing for the front-of-line equipment and a barrier to the surrounding environment. Additionally, it features
doors for loading parts, washer movement, and reject basket access. Although it is not directly involved in
pressing operations, it is custom designed and manufactured for dedicated use with the servo tandem press
line.
Classification under the Harmonized Tariff Schedule of the United States (HTSUS) is in accordance with the
General Rules of Interpretation (GRIs). GRI 1 provides that the classification of goods will be determined
according to the terms of the headings of the tariff schedule and any relative section or chapter notes. In the
event that the goods cannot be classified solely on the basis of GRI 1, and if the headings and legal notes do
not otherwise require, the remaining GRIs 2 through 6 will then be applied in order.
Regarding the servo tandem press line, Section XVI Note 4, HTSUS, addresses functional units. Specifically,
“Where a machine (including a combination of machines) consists of individual components (whether
separate or interconnected by piping, by transmission devices, by electric cables or by other devices) intended
to contribute together to a clearly defined function covered by one of the headings in Chapter 84 or Chapter
85, then the whole falls to be classified in the heading appropriate to that function.” It is the opinion of this
office that the subject press line satisfies the criteria of a functional unit, and its primary function is provided
for in heading 8462, HTSUS.
The applicable subheading for the servo tandem press line will be 8462.63.4030, HTSUS, which provides for
Machine tools (including presses) for working metal by forging, hammering or die forging (excluding rolling
mills); machine tools (including presses, slitting lines and cut-to-length lines) for working metal by bending,
folding, straightening, flattening, shearing, punching, notching or nibbling (excluding drawbenches); presses
for working metal or metal carbides, not specified above: Cold metal working presses: Servo-presses:
Numerically controlled: Other. The rate of duty will be 4.4% ad valorem.
The applicable subheading for the separately entered base plates will be 8466.94.6585, HTSUS, which
provides for Parts and accessories suitable for use solely or principally with the machines of headings 8456 to
8465, including work or tool holders, self-opening dieheads, dividing heads and other special attachments for
the machines; tool holders for any type of tool for working in the hand: Other: For machines of heading 8462
or 8463: Other: Bed, base, table, column, cradle, frame, bolster, crown, slide, rod, tailstock and headstock
castings, weldments or fabrications: Other. The rate of duty will be 4.7% ad valorem.
The applicable subheading for the separately entered front-of-line sound wall will be 8466.94.8585, HTSUS,
which provides for Parts and accessories suitable for use solely or principally with the machines of headings
8456 to 8465, including work or tool holders, self-opening dieheads, dividing heads and other special
attachments for the machines; tool holders for any type of tool for working in the hand: Other: For machines
of heading 8462 or 8463: Other: Other: Other. The rate of duty will be 4.7% 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 at https://hts.usitc.gov/.
You also requested a classification ruling regarding separately entered washer and oiler machines of
unknown origin. However, your inquiry does not provide enough information for us to rule on these items.
Your request for a classification ruling should include the country of origin, product brochure, detailed
narrative and/or flow chart to describe the purpose, function, and end-use application, clearly labeled
exploded and/or cutaway diagrams that display all components and how they articulate, information
regarding physical characteristics and dimensions, etc. When this information is available, you may wish to
consider resubmission of your request.
The holding set forth above applies only to the specific factual situation and merchandise description as
identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations
(C.F.R.), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the
information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and
complete in every material respect. In the event that the facts are modified in any way, or if the goods do not
conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and
Border Protection (CBP) and submit a request for a new ruling in accordance with 19 C.F.R. 177.2.
Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic
verification by CBP.
This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection
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, please contact
National Import Specialist Paul Taylor at [email protected].
Sincerely,
Steven A. Mack
Director
National Commodity Specialist Division