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NY 856896

Oct 31, 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 an electro static paint system 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 electro static paint system will be used to paint the final product (disc brake pads) to the required specifications of individual customers, i.e., vehicle manufacturers. The parts and the paint are electrostatically charged and the paint is thus drawn to the parts. The equipment is one machine with the components forming a functional unit. The drying operation is a secondary function to the spraying function. The steps in the operation are as follows:

1. Cured disc brake pads are manually loaded to a conveyor line which leads into the enclosed paint booth.

2. Disc brake pads are painted by means of a spraying operation.

3. Residual paint is collected and retained by means of a "water curtain" device.

4. Disc brake pads continue on the conveyor by moving into and through a furnace for proper drying and/or curing of the paint.

5. Disc brake pads are removed from this operation and transferred to the grinding operation.

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

The applicable subheading for the electro static paint system will be 8424.89.0080, Harmonized Tariff Schedule of the United States (HTS), which provides for 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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