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NY 856895

Oct 3, 1990



TARIFF NO.: 8424.89.0080

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

RE: The tariff classification of back plate treating equipment from Japan

Dear Mr. Beach:

In your letter dated September 28, 1990 you requested a tariff classification ruling. You have submitted a general layout schematic and photographs of the imported product.

The back plate treating equipment is used for the purpose of preparing metal backing plates for the hot molding (press curing) operation. Without this process, the final product would fail due to a lack of adhesion and also the possibility of corrosion over take. The equipment is one machine with the components forming a functional unit. The drying operation is a secondary function to the spraying. The steps in the preparation process are as follows:

1. Oil and grease are removed from the back plates in a solvent dip tank.

2. Any rust is removed with a shot-blast machine.

3. The back plate is cleaned and treated by a phosphate spraying system.

4. The adhesive is applied to the backplate using a spraying system.

5. The adhesive is dried using a low temperature furnace.

The steps in this process are linked together with an automated conveyor system.

The applicable subheading for the back plate treating equipment will be 8424.89.0080, Harmonized Tariff Schedule of the United States (HTS), which provides for other mechanical appliances (whether or not hand operated) for projecting, dispersing or spraying liquids or powders. The rate of duty will be 3.7 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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