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HQ 085988

December 5, 1989

CLA-2 CO:R:C:G 085988 JMH


TARIFF NO.: 9015.80.20

Mr. Donald P. Neubauer
Assistant Branch Manager
John v. Carr & Son, Inc.
P.O. Box 268
Buffalo, New York 14201

RE: Light-Log and Gyro-Log Survey System

Dear Mr. Neubauer:

Your letter of September 25, 1989, requesting a classification ruling on behalf of Techdel International, Inc. for the Light-Log and the Gyro-Log Survey Systems was referred to this office for a reply.


The merchandise in question, the Light-Log and the Gyro-Log Survey Systems, is imported from Canada and is used to determine the precise location of a drilled hole. The devices are used largely by exploring and mining companies. The survey systems allow the operator to know precisely where diamond drill holes are located throughout their entire length. This length can exceed a mile in any direction and can deviate by as much as a half mile.

The Light-Log system records the changes of direction in a drill hole by measuring the bending of a steel tube inserted into the drill hole. This is done by photographing a point of light on a target, the location of which is proportional to the amount of bend in the tube. With the Light-Log, photographs are taken at known intervals along the length of the hole and the information obtained is converted into the hole coordinates for these points. Using the known direction of the hole at the surface, the actual hole location in space can be calculated. In order to orient the target, an air bubble is photographed with the target. An inclinometer is included inside the instrument so that an inclination reading is photographed with the target.

The Light-Log is lowered down the drill hole on a drill-line by means of a winch. Measurements are photographed every ten feet along the length of the hole. A timing device activates the camera and advances the film. On completion of the hole survey, the film is removed from the instrument and developed. The information is then read from the film and converted by a computer to give the hole coordinates. The computer is not part of the Light-Log importation.

The inventory list for the Light-Log includes the following components: a probe consisting of the switch casing containing electronics, the switch arrangement, the light, and the target plates; the camera casing holding the dry gel anti-condensation container, the camera with rechargeable batteries, the film and the winding mechanism; spare "O" rings, a battery tester, grease, and a carrying case; a counter-timer including a battery charger and carrying case; a microfiche reader, overlay, and an instruction manual; traversers (2 x 10 ft.); spacers; and a survey kit including a developing can, a darkroom bag, a developer bottle, a stop bath bottle, a fixer bottle, and instructions.

The Gyro-Log functions similarly to the Light-Log. However, the Gyro-Log also utilizes a pendulum and a gyroscope. It is designed for use with holes drilled near vertical 85 to 90 degrees.


What is the proper classification for the Light-Log and the Gyro-Log Survey Systems under the Harmonized Tariff Schedule of the United States Annotated (HTSUSA)?


The classification of merchandise under the HTSUSA is governed by the General Rules of Interpretation (GRI's). GRI 1, HTSUSA, states in part that "for legal purposes, classification shall be determined according to the terms of the headings and any relative section or chapter notes..." The terms of the headings indicate that the appropriate heading for the Light-Log and Gyro-Log Survey Systems is heading 9015, HTSUSA. This heading describes:

9015 Surveying (including photogrammetrical surveying), hydrographic, oceanographic, hydrological, meteorological or geophysical instruments and appliances, excluding compasses, rangefinders, parts and accessories thereof...

9015.80.20 Other instruments and appliances... Optical instruments and appliances...

The Light-Log and the Gyro-Log are specifically designed instruments which perform a surveying function. Therefore, it is the opinion of this office that these surveying systems are to be classified within subheading 9015.80.20, HTSUSA.


The Log-Light and the Gyro-Light Surveying Systems are properly classified within subheading 9015.80.20, HTSUSA. Since the goods originate and are imported from Canada, the rate of duty is 5.0 percent ad valorem according to the United States- Canada Free Trade agreement upon compliance with all regulations.


John Durant, Director
Commercial Rulings Division

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