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NY N011556

June 20, 2007



TARIFF NO.: 8463.30.0080

Ms. Yolanda Given
Comtech North America
PO Box 309
Bloomfield Hills, MI 48303

RE: The tariff classification of a spring coiler from Sweden.

Dear Ms. Given:

In your letter dated May 15, 2007, you requested a tariff classification ruling.

The literature included with your submission describes a spring coiler (Colombi C4 Series) used for the in-line production of compression springs and tension springs. The Colombi C4 Series is further described as being equipped with one or two pairs of feeder rollers for wire up to .55mm. The specifications for the machine are as follows: Capacity: 30 – 120 minutes, Coiler Weight: 45kg net, Control Weight: 85kg net, Voltage: 324 – 528 V3 phase, Rated current: 16 amp, Air pressure: 5.5 bar minute.

In a subsequent submission to this office on June 14, 2007, values for the CNC Spring Coiler (Colombi C4 Series) were listed as each model being valued over $3025.

The applicable subheading for the spring coiler (Colombi C4 Series) will be 8463.30.0080, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Other machine tools for working metal or cermets, without removing material: Machines for working wireOther. The duty rate will be 4.4 percent ad valorem.

Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.

Your inquiry does not provide enough information for us to give a classification ruling on various spare parts you listed for the spring coil machine. Your request for a classification ruling should include the following:

A labeled schematic showing precisely where each part will be used in the machine. Do the cutting parts of Mandrel Arbor, the Cutter Carbide and the Pitch Tool contain by weight over 0.2 percent of chromium, molybdenum, or tungsten or over 0.1 percent vanadium? Will these parts be imported with the spring coiler or imported separately? What is the function of the pitch tool? How does it operate?

When this information is available, you may wish to consider resubmission of your request. We are returning any related exhibits, etc. If you decide to resubmit your request, please include all of the material that we have returned to you.

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 Patricia O’Donnell at 646-733-3011.


Robert B. Swierupski

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