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NY 859753

Feb. 19, 1991

CLA-2-85:S:N:N1:103 859753


TARIFF NO.: 8515.21.0000; 9030.39.0040

Mr. Scott A. Cohn
Grunfeld, Desiderio, Lebowitz & Silverman 12 East 49th Street
New York, N.Y. 10017

RE: The tariff classification of armature and stator manufacturing machines from Italy

Dear Mr. Cohn:

In your letter dated January 21, 1991 on behalf of Axis USA, Inc. you requested a tariff classification ruling.

This request represents one of several ruling requests you have submitted covering the importation of various machines for the manufacture of armatures and stators. The armatures and stators made by this equipment will be used as components of electric motors for small household appliances, power tools, and automobile DC motors.

Armatures basically consist of coils of wire wound around an iron core. They are produced by assembling metal laminations, or stacks, into a cylindrical shape and then inserting a shaft into slots in the stacks. A commutator, consisting of a molded plastic ring surrounded by a copper shell, is then placed onto the end of the shaft, and wires are wound around the shaft and fused to the commutator. During this process insulating materials are inserted at various stages so as to protect the armature components and wires, and the wires are coated with a resin to protect them from dirt and wear. Finally, the electrical connections in each completed armature are tested. The armatures are transported on metal pallets along a conveyor system from machine to machine as the assembly process occurs. Stators, which are stationary parts of a motor about which a rotor revolves, are produced in much the same fashion.

You inquired about the following specific articles:

1. Model SBM stator bonding machine - a machine which utilizes resistance heating from low voltage electrodes to melt the insulation on copper wires, thus bonding the wires together.

2. Model STS stator testing machine - an electrical probe which measures resistance in order to test the quality of the wire bond. It is not equipped with a recording device.

3. Model SBT stator bonder tester - a machine which both bonds the copper wires by means of resistance heating and electrically tests the quality of the bond.

Control panels for each machine described above may also be imported with the particular machine.

The applicable subheading for the Model SBM stator bonding machine and the Model SBT stator bonder tester will be 8515.21.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for machines and apparatus for electric resistance welding of metals: fully or partly automatic. The rate of duty will be 2 percent ad valorem.

The applicable subheading for the Model STS stator testing machine will be 9030.39.0040, HTS, which provides for other instruments and apparatus for measuring or checking voltage, current resistance or power, without a recording device. The rate of duty will be 4.9 percent ad valorem.

A control panel imported together with the machine it will control will be classified in the same subheading as the machine. The above merchandise is not subject to any Voluntary Restraint Agreements or visa requirements.

In a supplemental letter dated January 31, 1991 you also inquired about disassembled machines and parts. In the absence of specific information, we are unable to provide you with a ruling on these matters. However, for your information, a particular heading for an article includes such an article in a disassembled state, per General Rule of Interpretation 2(a). If the importation does not contain all the components of the disassembled article, it will still be classified in the heading for the complete article provided it has the essential character of the complete article. Parts of articles, and spare parts, which are not goods provided for in any of the other headings of chapters 84, 85 or 90, nor excluded from chapters 84, 85 or 90, will be classified in the same heading as the article of which they are a part provided they are solely or principally used with such article (see Notes 1 and 2 of section XVI, Note 1 of chapter 84, Note 1 of chapter 85, and Notes 1 and 2 of chapter 90, HTS).

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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