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NY 885988

JUNE 01, 1993

CLA-2-84:S:N:N1:105 885988


TARIFF NO.: 8515.80.0080, 9018.90.6000

Mr. Terrence L. Mc Cracken
R.J. Mc Cracken CHB
5345 44th Street, S.E.
Grand Rapids, MI 49512-4001

RE: The tariff classification of heating equipment from Switzerland

Dear Mr. Mc Cracken:

In your letter dated May 3, 1993 you requested a tariff classification ruling on behalf of Hill Machinery Company.

You submitted four brochures covering the following four classes of heat machines: Leister sterile hot air jet; Leister- Labor "S" for dental technicians and dentists; Leister hand-held welding tools for welding thermoplastics; and Labor "S" not air tools for the restorer, conservator, and the laboratory.

The sterile hot air jet, called the Leister Hot Air Coagulator, is an electrically operated device that blows air through a heating element to produce a jet of hot air, whose temperature and volume can be finely adjusted from 200 to 500 C. and from 3 to 30 liters per minute respectively. This hand held instrument is used for hemostasis, coagulation and shrinking of tissue in human and veterinary surgery.

The Labor "S" is shown not only in leaflet 42 directed to dental technicians and dentists, but also in leaflet 21A on hand held welding tools and in leaflet 40 on tools for restorers, conservators and laboratories. It thus appears to be a versatile tool not principally used in dental work.

The hand-held welding tools shown in the submitted brochure include: the Leister-Labor "S", the Leister-Diode, and the Leister- Triac. The Diode and Triac appear to be chiefly used for welding of thermoplastics such as PVC, polyethylene, polypropylene, acrylics, and polycarbonate. The most frequently used methods of hot air welding done with these tools are pendulum welding, speed welding and mirror welding. The Labor "S", on the other hand, appears to have a multitude of uses.

The hot air tools for the restorer, conservator, and the laboratory are the Leister-Labor "S" and the Leister Ghibli. Both have a variety of uses: the Labor "S" as a Bunsen burner in a lab; in securing detached paint layers on an oil painting; in removing paint, glue and putty; and in welding and soldering; the Ghibli: in undoing old glued repairs on earthenware; removing old paint from doors, furniture and walls; and welding thermoplastics.

The applicable subheading for the Leister-Diode and Leister- Triac will be 8515.80.0080, Harmonized Tariff Schedule of the United States (HTS), which provides for electric (including electrically heated gas) welding machines and apparatus, whether or not capable of cutting: other. The duty rate will be 2 percent ad valorem.

The applicable subheading for the Leister Hot Air Coagulator will be
9018.90.6000, HTS, which provides for electro-surgical instruments and appliances . . . and parts and accessories thereof. The duty rate will be 7.9 percent ad valorem.

The question of classification for the Labor "S" and the Ghibli is being referred to the Office of Regulations and Rulings, U.S. Customs Service Headquarters, 1301 Constitution Avenue, N.W., Washington D.C. 20229. A ruling will be issued to you from that office.

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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