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NY 856876

Oct. 24, 1990

CLA-2-84:S:N:N1:103 856876


TARIFF NO.: 8474.80.0015; 8480.60.0010; 8479.89.9090

Mr. Paul Beach
Nuturn Corporation
Automotive Products Division
1 Grizzly Lane
Smithville, Tn. 37166

RE: The tariff classification of presses and dies from Japan

Dear Mr. Beach:

In your letter dated Sept. 28, 1990 you requested a tariff classification ruling.

You state your firm intends to import production equipment to be used in the manufacture of automotive disc brake pads. Materials used in the manufacture of the pads includes fibers such as kevlar and steel, binders such as rubber and resins, and friction modifiers including graphite and carbon. The exact ratio of the materials is based on specific vehicle parameters such as weight distribution and inertia. These materials are mixed together and molded to a steel back plate to form the disc brake.

The specific items on which you request a classification ruling are a preform press, a hot forming press, and dies used in these machines. The preform press is a 30-ton press which utilizes hydraulic pressure in order to compress the raw materials into the proper brake shape. A preform die, which has previously been filled with the desired amount of raw materials, is shuttled into the preform press prior to commencement of the pressing operation. The hot forming press provides pressure and heat for a specific period of time in order to both compress and cure the preformed material, as well as to adhere it to the back plate. The hot forming press may be programmed to proceed through its operating cycle based on specified time, temperature, and pressure parameters. The brake pads are then taken to a furnace for final baking.

Preforming and cure press dies are molds used in conjunction with the presses described above. The preform die contains two cavities and imparts its shape to the material during the initial pressing operation. The number of cavities in the cure press die, used during compression, curing and back plate adhesion, will vary based on the final product size.

The applicable subheading for the preform press will be 8474.80.0015, Harmonized Tariff Schedule of the United States (HTS), which provides for other machinery for shaping or molding mineral products in powder or paste form. The rate of duty will be 2.9 percent ad valorem. The applicable subheading for the hot forming press will be 8479.89.9090, HTS, which provides for other machines and mechanical appliances having individual functions, not specified or included elsewhere. The rate of duty will be 3.7 percent ad valorem. Finally, the preform and cure press dies are classifiable in the provision for injection or compression type molds for mineral materials in subheading 8480.60.0010, HTS, and are dutiable at the rate of 3.9 percent ad valorem.

This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177).

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.


Jean F. Maguire
Area Director

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