CLA-2:OT:RR:NC:N1:104
Rhonda Riley-Thayer
Supply Chain Solutions, LLC
4607 44th St. SE
Grand Rapids, MI 49512
RE: The tariff classification of Butterfly Mixing Systems from Germany
Dear Ms. Riley-Thayer:
In your letter dated January 20, 2026, you requested a tariff classification ruling.
The subject items are two industrial mixing systems that will be used in the production of sealants, adhesives,
and coatings (e.g., silicone, acrylic, and polyurethane) for use in the chemical, coatings and polymer
industries. Each system will consist of multiple machines and equipment that are interconnected via a central
control system and arranged together to directly support the mixing operation, as follows:
- Vacuum butterfly mixer with a vacuum system
- Human-machine interface (HMI) mounted on the mixer
- Electrical cabinet for mixer
- Vacuum pump for mixer
- Dosing units for automatic discharging/emptying of chalk or silica from super sacks or big bags,
specifically designed to feed the mixing systems
- Electrical panel/cabinet for dosing units
- Pump for powder dosing
- Integrated powder dosing transfer system including screw conveyor/feeder for transporting primary
chalk/material to mixing unit
- Electrical panel/cabinet for powder dosing unit
- Four (4) stainless steel mixing containers tailored specifically to the mixer
- Hydraulic container press for pushing out manufactured materials from the mixer
- Electrical panel/cabinet for container press
- Integrated floor scale for weighing the dosed materials
The mixing systems are designed for semi-autonomous operation, under human supervision and control. The
formulation of sealants and adhesives requires the addition of various liquid and solid raw materials, which
are then mixed under specific conditions, including mixing speed, pressure, and controlled temperature (heat
resulting from stirring action), until a homogeneous mass is formed for further processing.
During the production process, various liquid raw materials are fed in from external tank farms and bulk
containers via the central control systems. Chalk is fed in as a filler from big bags or super sacks via the chalk
dosing station. In the production of silicone, silica is dosed as a thickener for many products. The integrated
scale is required as a weighing/measuring instrument or for control purposes, e.g., for dosing via flow
measurements for liquid substances, for both the dosing of solids and liquids. Vacuum pumps contained in
the system generate the pressure conditions required in the containers during mixing. You indicate that the
mixer shaft can be equipped with various attachments; as imported, a butterfly mixer and a dissolver disc are
included with the mixing system.
You state that each mixing system will be imported complete in multiple containers, in a single shipment.
Certain components of the system may be unassembled at the time of importation.
In your submission, you suggest that the each imported mixing system be classified in subheading
8479.82.0040. We agree.
For large-scale plants consisting of several machines, or multi-machine production lines, we must consider
note 4 to Section XVI, Harmonized Tariff Schedule of the United States (HTSUS), which provides: 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.
We consider the imported mixing systems to constitute a single functional unit, with a clearly defined
function of mixing materials to produce sealants, adhesives, and coatings. All machinery and equipment
imported with the system is interconnected and designed to work together. Mixing machines are covered in
Chapter 84 under heading 8479, HTSUS.
Pursuant to GRI 1 (note 4, Section XVI), GRI 2(a), and GRI 6, the applicable subheading for mixing
systems, when imported together in one shipment, will be 8479.82.0040, 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: Mixing, kneading, crushing, grinding,
screening, sifting, homogenizing, emulsifying or stirring machines: Mixing, kneading or stirring machines.”
The general rate of duty will be free.
The duties cited above are current as of this ruling’s issuance. 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/.
This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other
charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other
duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the
classification stated above, the merchandise covered by this ruling may also need to be reported with either
the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions
covering exceptions to such tariffs.
For further information to assist with the importation process, please refer to the frequently updated Cargo
Systems Messaging Service (CSMS) messages at
https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and Frequently Asked Questions on
the Trade Remedy/IEEPA page at
https://www.cbp.gov/trade/programs-administration/trade-remedies/IEEPA-FAQ.
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
(CFR), 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 CFR 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 Arthur Purcell at [email protected].
Sincerely,
(for)
Denise Faingar
Designated Official Performing the Duties of the Division Director
National Commodity Specialist Division