The tariff classification of a cold forming assembly machine from Germany

Product description

You state that the machine, model RWT-Rolling System MDS Hy CNC, rolls a piston onto a shaft via hydraulic rollers and pressure. The machine includes a complete electrical cabinet, frequency converter, lamp, cooling equipment, 1 set of spacers and 1 set of rolling dies. A copy of the manufacturer’s offer has been submitted. In addition to the price and terms, it describes some of the special equipment included and provides some technical data. In a faxed letter of July 10, 2003 in response to a request for a description of the cold forming operation, Mr. Phillip Zinn of Cooper Tools replied as follows: “The shaft is also referred to as the steering rack. On the steering rack, there are two grooves. In a prior assembly, a clip ring is assembled on one of the grooves. The piston is then slid over the steering rack, coming to rest against the clip ring, thus stopping the piston from further movement in one direction. The steering rack is placed in a holding fixture to obtain the correct position. The rollers of the machine move downward to apply pressure on the flange of the piston. At this point the flange is straight and is parallel to the horizontal surface of the steering rack. As the steering rack rotates or spins, the pressure applied by the roller increases and cold forms the parallel surface of the piston down into the second groove, thus preventing the piston from moving along the steering rack in either direction.” Mr. Zinn also provided a picture of a representative machine and a drawing of the shaft and piston after the piston is attached to the steering rack. It is suggested that this machine should be classified under HTS subheading 8479.89.9897 which provides for machines and mechanical appliances having individual functions, not specified or included elsewhere in this chapter. The cold forming performed by this machine is essentially a metal bending operation. Since this machine is included elsewhere in this chapter, heading 8479 cannot apply.

CBP rationale

fixture to obtain the correct position. The rollers of the machine move downward to apply pressure on the flange of the piston. At this point the flange is straight and is parallel to the horizontal surface of the steering rack. As the steering rack rotates or spins, the pressure applied by the roller increases and cold forms the parallel surface of the piston down into the second groove, thus preventing the piston from moving along the steering rack in either direction.” Mr. Zinn also provided a picture of a representative machine and a drawing of the shaft and piston after the piston is attached to the steering rack. It is suggested that this machine should be classified under HTS subheading 8479.89.9897 which provides for machines and mechanical appliances having individual functions, not specified or included elsewhere in this chapter. The cold forming performed by this machine is essentially a metal bending operation. Since this machine is included elsewhere in this chapter, heading 8479 cannot apply. The applicable subheading for the cold forming assembly machine, model RWT-Rolling system MDS Hy CNC will be 8462.21.8085, Harmonized Tariff Schedule of the United States (HTS), which provides for machine tools (including presses) for working metal by bending, folding, straightening, flattening, shearing, punching or notching; … bending, folding straightening or flattening machines (including presses): numerically controlled: other. The rate of duty will be 4.4 percent.

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