The tariff classification of button assembly machines from Holland

NY G84181 November 29, 2000 CLA-2-84:RR:NC:1:103 G84181 CATEGORY: Classification TARIFF NO.: 8479.89.9797 Mr. David J. Hendrickson U.S.A. Buttons, Inc. 175 Progress Drive West Bend, WI 53095 RE: The tariff classification of button assembly machines from Holland Dear Mr. Hendrickson: In your letter dated October 31, 2000 you requested a tariff classification ruling. With your inquiry you submitted a sales brochure and other information describing hand operated machines used to assemble pin-type metal buttons for such typical applications as political campaigns, sports events, and advertising. The machines basically consist of a base for resting on a table or workbench, upper and lower die pressing plates, and a lever-like handle. To operate the machines a metal button shell, along with the desired artwork and a clear mylar plastic covering, are initially placed onto the die plate. The handle is then pulled down, crimping the pieces together in the upper die. The metal back, with its spring pin or spring lock pin already attached, is then placed in the lower die and the handle is again pulled down, forcing the back into the shell and thus producing the finished button. The buttons are intended to be pinned onto various articles of wearing apparel. The sales brochure depicts four button assembly machines. The Machine 150 is designed to produce buttons 2¼ inches in diameter, and on average can assemble 120 buttons per hour. The Machine 300 can accommodate dies from 1 inch to 3 inches in diameter, and can produce about 250 buttons per hour. The Machine 600 utilizes round, oval, oblong, square or rectangular dies from 1 to 3½ inches in size, and can assemble 400 buttons per hour. Finally, the Machine 500 combines the button assembly unit with a cutter which cuts the artwork from a sheet by means of separate cutting dies. The applicable subheading for the button assembly machines described above will be 8479.89.9797, Harmonized Tariff Schedule of the United States (HTS), which provides for machines and mechanical appliances having individual functions, not specified or included elsewhere (in Chapter 84): other machines and mechanical appliances: other: other: other: other. The rate of duty will be 2.5 percent ad valorem. 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. Sincerely, Robert B. Swierupski Director, National Commodity Specialist Division