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NY A86781

September 17, 1996

CLA-2-84:RR:NC:1:103 A86781


TARIFF NO.: 8428.90.0010; 8460.90.8080; 8466.10.0070; 8537.10.9060

Mr. Dennis Heck
Yamaha Corporation of America
PO Box 6600
Buena Park, CA 90622-6600

RE: The tariff classification of finishing robots from Japan

Dear Mr. Heck:

In your letter dated August 16, 1996 you requested a tariff classification ruling.

Your firm intends to import various models of robots, along with ancillary equipment such as tool heads, holders, and feeders, for use in polishing and deburring operations. The importations may consist of complete systems, or the individual items may be separately imported.

Models Tau-One (T-I) and Kappa-Two (K-II) will be principally used to grip workpieces and manipulate the workpieces against a finishing tool head. Both are 6-axis robots capable of holding up to 50 kilograms, and have a repeatability of plus or minus .1 millimeter. They utilize AC servo motors and are sealed to protect them from grit and dust. They will be imported with a programmable 200-volt automatic compensation controller which incorporates load feedback control and offset/thrust feedback control, as well as a synchronized teaching unit.

The Zeta-Two (Z-II) and Zeta-Two Hexa (Z-II6) finishing robots will be used to hold and manipulate deburring and buffing tools against a workpiece. The Z-II is a five-axis robot, while the Z-II6 features 6 axes of movement. The former is specially designed for deburring and high speed finishing of larger workpieces, while the latter is specially designed for polishing, deburring, surface finishing, grooved finishing, and internal cutting of workpieces. The automatic compensation controller imported with these models incorporates thrust force control and tool speed feedback parameters. These robots will be used with either a model RF radial floating tool holder, which is specially adapted to hold rotary burrs and similar tools, or a model TF thrust floating tool holder, specially adapted to disc type tools. The RF tool holder allows compensation in the radial direction of the shaft, while the TF tool holder allows compensation so that the tool can float in the direction of the shaft.

The applicable subheading for the T-I and K-II handling robots, whether imported separately or with their controller and/or teaching unit, will be 8428.90.0010, Harmonized Tariff Schedule of the United States (HTS), which provides for other lifting, handling, loading or unloading machinery: other machinery: other: industrial robots. The duty rate will be 1.2 percent ad valorem.

The applicable subheading for the Z-II and Z-II6 polishing and deburring robots, whether imported separately or with their controller, teaching unit and tool holder, will be 8460.90.8080, HTS, which provides for machine tools for deburring, sharpening, grinding, honing, lapping, polishing or otherwise finishing metal or cermets by means of grinding stones, abrasives or polishing products...: other: other: other. The duty rate will be 4.4 percent ad valorem.

The applicable subheading for the RF and TF tool holders, imported separately, will be 8466.10.0070, HTS, which provides for parts and accessories suitable for use solely or principally with the machines of headings 8456 to 8465...: tool holders and self-opening dieheads: other. The duty rate will be 4.5 percent ad valorem.

Finally, the applicable subheading for the programmable automatic compensation controller, imported separately, will be 8537.10.9060, HTS, which provides for boards, panels, consoles, desks, cabinets and other bases, equipped with two or more apparatus of heading 8535 or 8536, for electric control...: for a voltage not exceeding 1,000 V: other: programmable controllers. The duty rate will be 4.3 percent ad valorem.

Your inquiry does not provide enough information for us to give a classification ruling on Z-II and Z-II6 robots imported together with the various tool heads, or with the tool heads, auto tool feeder, and teaching unit imported separately. Your request for a classification ruling for the various tool heads and the auto tool feeder should include the following information:

- a more detailed description of their use, including specifications and price;

- a statement as to whether they are floor or bench mounted;

- a statement indicating how they are controlled; and

- a statement as to whether the buffing head removes any material.

Your request for a classification ruling for the teaching unit should include the following information:

- a more detailed description of its function and operation;

- a description of its operating system and the type of CPU chip it contains;

- a statement as to whether it meets all four criteria found in Note 5(A)(a) to Chapter 84; and

- a statement as to whether it is comparable to a programmable controller.

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

A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist Alan Horowitz at 212-466-5494.


Roger J. Silvestri

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