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NY 873367

May 4, 1992

CLA-2-84:S:N:N1:103 873367


TARIFF NO.: 8428.90.0010

Mr. Anthony Duryea
Davy McKee Corporation
One Oliver Plaza
Pittsburgh, PA 15222-2682

RE: The tariff classification of a ladle shroud manipulator robot from the United Kingdom

Dear Mr. Duryea:

In your letter dated April 9, 1992 you requested a tariff classification ruling.

The ladle shroud manipulator robot is mounted onto a work platform erected next to the continuous caster. The ladle shroud manipulator robot is used to grip a shroud (tube), rotate, and place the shroud between a ladle and a tundish in order to prevent air or other contaminants from coming into contact with the molten steel. Once the shroud is properly positioned and engaged onto the valve nozzle at the bottom of the ladle, the liquid steel can flow into the tundish. Each time a new ladle with molten steel is placed in the continuous caster, the robot transfers and positions a new shroud so that the pour can commence. The shrouds are stored in interchangeable racks which are also located on the platform.

The robot controller allows the robot to be operated manually, semi-automatically, or automatically. In the manual mode the movements of the robot are controlled by means of two joysticks. In the semi-automatic mode the robot automatically transfers the shroud beneath the ladle, and the operator then uses the joysticks to manipulate and engage the shroud onto the ladle gate valve. Finally, in the automatic mode the robot locates the ladle valve using a laser incorporated in the robot and automatically positions and engages the shroud. According to the information submitted with your letter, two robots and one controller unit will be imported, with the second robot used as a replacement for the working robot in the event of a breakdown.

You claim the ladle shroud manipulator robot should be classified in the provision for parts of casting machines in subheading 8454.90.0060, Harmonized Tariff Schedule of the United States (HTS), and free of duty.

The General Rules of Interpretation provide the principles which govern the classification of imported merchandise under the HTS. GRI 1 states that classification of imported articles shall be determined according to the terms of the headings and any relative section or chapter notes. Note 2(a) to section XVI, the section which encompasses casting machines and parts thereof, states that parts which are goods included in any of the headings of chapters 84 and 85 (other than headings 8485 and 8548) are in all cases to be classified in their respective headings. Thus the applicable subheading for the ladle shroud manipulator robot(s), together with their controller, will be 8428.90.0010, HTS, which provides for other lifting, handling, loading or unloading machinery: other machinery: other: industrial robots. The rate of duty will be 2 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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