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NY 849480

CLA-2-90:S:N:N1:114 849480


TARIFF NO.: 9031.40.0080

Mr. John Douglas, Marketing Manager
Industrial & Research Measurement Systems, Inc. (I.R.M.)
Carnegie Office Park
Building 1, Suite 230
600 North Bell Avenue
Carnegie, Pennsylvania 15106

RE: The tariff classification of the I.R.M. ROMETER hot-strip flatness gage from Belgium.

Dear Mr. Douglas:

In your letter dated February 2, 1990, you requested a tariff classification ruling.

The product for which you request a classification is the I.R.M. ROMETER--a laser-based flatness gage for measuring on-line flatness defects in hot strips. These gages are for use by hot strip mills to accurately measure on-line flatness of steel strips to an internationally accepted threshold. Among the major industries utilizing steel strips is the automotive industry.

The applicable subheading for the I.R.M. ROMETER flatness gage will be 9031.40.0080, Harmonized Tariff Schedule of the United States (HTS), which provides for other optical measuring or checking instruments and appliances. The rate of duty will be 10 percent ad valorem.

This ruling is being issued under the provisions of Section 177 of the Customs Regulations (19 C.F.R. 177).

You indicate in your letter that the I.R.M. ROMETER flatness gage is priced at $668,493, of which $68,000 consists of U.S.-made parts. These parts include the following: lasers; power supply; CRT unit; color printer; electronic board chips; and CCD cameras. Your letter gives no details as to the assembly operation involved when these parts are shipped from the United States to Belgium. Therefore, we are unable to advise you as to the applicability of Subheading 9802.00.8050, HTS, which is detailed in the next paragraph. Subheading 9802.00.8050, HTS, applies to articles assembled abroad in whole or in part of fabricated components, the products of the United States, with no operations performed thereon except the attachment of the components to form the imported merchandise and operations incidental thereto. An article classified under Subheading 9802.00.8050, HTS, is subject to duty upon the full appraised value of the imported article, less the cost or value of such products of the United States.

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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