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NY F88976

July 20, 2000

CLA-2-84:RR:NC:1:103 F88976


TARIFF NO.: 8428.90.0010

Mr. James S. O’Kelly
Barnes, Richardson & Colburn
475 Park Avenue South
New York, NY 10016

RE: The tariff classification of a robot system from Sweden

Dear Mr. O’Kelly:

In your letter dated June 27, 2000 on behalf of ABB Flexible Automation, Inc. you requested a tariff classification ruling.

Your client intends to import a specially designed robot system to move and palletize mail containers for the United States Postal Service. Literature submitted with your inquiry indicates the robot system will consist of model IRB 840 gantry robot, a control cabinet programmed to operate the robot, cables and connectors for attaching the control cabinet to the robot, and a material handling gripper. The IRB 840 robot system will be used for high throughput handling and palletizing of trays and tubs filled with mail. The system utilizes an innovative double robot and gantry design with each gantry divided into two zones, allowing one side of the gantry to continue operating while the other side undergoes pallet exchange or maintenance. The zip-coded trays or tubs, weighing from 15 to 70 pounds each, are transported past a bar code scanner by a separate conveyor and are then moved to one of two pickup positions. The bar code is communicated to the robot system controller, which in turn directs one of the twin gantry robots to pick up and place the tray or tub onto the appropriate pallet. The unique gripper attached to the robot arm senses and handles intermixed trays and tubs automatically. The system is capable of handling up to 15 mail containers per minute.

According to your letter, the gripper will be of United States origin and will be shipped to Sweden without charge by your client. In Sweden the gripper will be placed in the same container as the Swedish-made robot and control cabinet and then the entire system will be exported to the United States.

The applicable subheading for the robot system, consisting of an IRB 840 gantry robot, its control cabinet, the necessary cables and connectors, and a handling gripper, imported in a single shipment and forming a functional 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 rate of duty will be free.

It should be noted that any software on media imported with the robot system is separately classifiable in accordance with note 6 to chapter 85, HTS. Note 6 to chapter 85 states that records, tapes and other media of heading 8523 or 8524 remain classified in those headings, whether or not they are entered with the apparatus for which they are intended.

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 212-637-7027.


Robert B. Swierupski

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