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HQ 964755

DECEMBER 5, 2001

CLA-2 RR:CR:GC 964755 JAS


TARIFF NO.: 8207.50.20, 8207.90.30

Tommy Hoang
EMO Trans L.A., Inc.
1100 Hindry Ave.
Los Angeles, CA 90045

RE: NY E84599 Revoked; Drill Bits and Router Bits

Dear Mr. Hoang:

In NY E84599, which the Director of Customs National Commodity Specialist Division, New York, issued to you on July 15, 1999, on behalf of Ham Technology, certain drill bits and router bits for machines used to manufacture printed circuit boards were found to be classifiable in provisions of heading 8207, Harmonized Tariff Schedule of the United States (HTSUS), as tools for drilling, other than rock drilling, and as other interchangeable tools, respectively.

Pursuant to section 625(c), Tariff Act of 1930 (19 U.S.C. 1625(c)), as amended by section 623 of Title VI (Customs Modernization) of the North American Free Trade Agreement Implementation Act, Pub. L. 103-182, 107 Stat. 2057, 2186 (1993), notice of the proposed revocation of NY E84599 was published on October 31, 2001, in the Customs Bulletin, Volume 35, Number 44. No comments were received in response to that notice.


The drill bits and router bits were described in NY E84599 as being for use in the printed circuit board industry and as being unsuitable for cutting metal. No further description was provided. These tools are for drilling and routing machines used in the manufacture of printed circuit boards. Literature
submitted with the ruling request described solid carbide high performance micro drills, special drills and special drills with stainless hardened steel shanks. Shank diameter, total length, and other dimensions were specified, but the composition of the cutting part of the tools was not indicated.

The HTSUS provisions under consideration are as follows:

8207 Interchangeable tools for handtoolsor for machine-toolsand rock drilling or earth boring tools; base metal parts thereof:

8207.50 Tools for drilling, other than for rock drilling, and parts thereof:

8207.50.20 With cutting part containing by weight over 0.2 percent of chromium, molybdenum, or tungsten or over 0.1 percent of vanadium

Other, not suitable for cutting metal:


8207.90 Other interchangeable tools, and parts thereof:

8207.90.30 Other cutting tools with cutting part containing by weight over 0.2 percent of chromium, molybdenum, or tungsten or over 0.1 percent of vanadium


8207.90.75 Other


Determining the composition of the cutting parts of the drill bits and router bits.


Under General Rule of Interpretation (GRI) 1, Harmonized Tariff Schedule of the United States (HTSUS), goods are to be classified according to the terms of the headings and any relative section or chapter notes, and provided the headings or notes do not require otherwise, according to GRIs 2 through 6.

The Harmonized Commodity Description and Coding System Explanatory Notes (ENs) constitute the official interpretation of the Harmonized System at the international level. While not legally binding, the ENs provide a commentary on the scope of each heading of the HTSUS and are thus useful in ascertaining the classification of merchandise under the System. Customs believes the ENs should always be consulted. See T.D. 89-80, 54 Fed. Reg. 35127, 35128 (Aug. 23, 1989).

The ENs on p.1204 in part state that the tools of heading 8207 may be either one-piece or composite articles. The one-piece tools, made wholly from one material, are generally of alloy steel or steel with a high carbon content. Composite tools consist of one or more working parts of base metal, of metal carbides or of cermets, of diamond or of other precious or semi-precious stones, attached to a base metal support, either permanently, by welding or insetting, or as detachable parts.

The classifications expressed in NY E84599 were those recommended in your ruling request of July 8, 1999. Subsequently, however, Ham Technology responded to a facsimile inquiry, dated October 26, 2000, from Customs New York office and provided a safety data sheet on the material from which these bits are made. Under the designation Hardmetal, the data sheet indicates the material may also be referred to as cemented carbide or tungsten carbide, the latter with from 3% to 25% cobalt. Similar information from another technical source on carbide tools and related carbide products is a specification identifying a substance with the chemical name “tungsten carbide product with cobalt binder,” known variously as Hard Metal, Cemented WC and tungsten carbide. This material is used, among other things in metalworking tools. The specification indicates, for example, that tools of this material are between 2 to 30 percent by weight cobalt and between 70-98 percent, by weight, tungsten carbide. The available evidence now suggests that the drill bits and router bits the subject of NY E84599 may have cutting parts with the requisite percent by weight of tungsten specified in subheadings 8207.50.20 and 8207.90.30, HTSUS.


Under the authority of GRI 1, drill bits and router bits the subject of NY E84599 are provided for in heading 8207. The drill bits are classifiable in subheading 8207.50.20, HTSUS, and the router bits in subheading 8207.90.30, HTSUS.


NY E84599, dated July 15, 1999, is revoked. In accordance with 19 U.S.C. 1625(c), this ruling will become effective 60 days after its publication in the Customs Bulletin.


John Durant, Director
Commercial Rulings Division

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