The tariff classification of industrial glue guns from Taiwan

N007738 March 23, 2007 CLA-2-84:RR:E:NC:1:104 CATEGORY: Classification TARIFF NO.: 8479.89.9897 Ms. Vanessa Rambo Bostik, Inc. 11320 Watertown Plank Road Wauwatosa, WI 53226 RE: The tariff classification of industrial glue guns from Taiwan Dear Ms. Rambo: In your letter dated March 1, 2007 you requested a tariff classification ruling. The hot melt glue guns, i.e., Item K560000, Model TG-560 (120V-22W) and Item K760000, Model TG-760 (120V-300W-0.45DIA), are not designed for household/domestic use but rather for use in industrial applications such as assembly and packaging. The glue guns do not have self-contained electrical motors nor do they utilize batteries. The devices are plugged into standard U.S. 120-Volt AC outlets. Using an internal thermostat, the feed tube is heated to the desired temperature. This enables a glue stick to be warmed and softened so that it will advance easily through the feed tube. The glue stick is fed through the feed tube and expelled from the glue gun by means of a mechanical trigger action. Model TG-560 has a discharge rate of 0.7~1.2 kg/hr. It features an adjustable temperature of 240-4200 F with a heating time of 2~3 minutes. The model’s dimensions are 275 x 185 x 55 mm with a weight of 0.62 kg. Model TG-760 has a discharge rate of 1.0~1.5 kg/hr. It also features an adjustable temperature of 240-4200 F with a heating time of 2~3 minutes. The model’s dimensions are 280 x 215 x 55 mm with a weight of 0.70 kg. In your letter, you suggest that the glue guns should be classified under subheading 8515.19, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Electric (including electrically heated gas), laser or other light or photon beam, ultrasonic, electron beam, magnetic pulse or plasma arc soldering, brazing or welding machines and apparatus, whether or not capable of cutting; electric machines and apparatus for hot spraying of metals or cermets; parts thereof: Brazing or soldering machines and apparatus: Other. You also suggest that the glue guns should be classified under subheading 8424.20.9000, HTSUS, which provides for Mechanical appliances (whether or not hand operated) for projecting, dispersing or spraying liquids or powders; fire extinguishers, whether or not charged; spray guns and similar appliances; steam or sand blasting machines and similar jet projecting machines; parts thereof: Spray guns and similar appliances: Other. The glue guns in question do not perform a soldering function. In addition, they are neither spray guns nor similar appliances of heading 8424. The heat generated merely activates the hot melt. Dispensing (not dispersing) is the principal function of the glue guns. Thus, neither subheading 8515.19, HTSUS, nor subheading 8424.20.90, HTSUS, is applicable in this instance. The applicable subheading for the hot melt glue guns, i.e., Item K560000, Model TG-560 (120V-22W) and Item K760000, Model TG-760 (120V-300W-0.45DIA) will be 8479.89.9897, HTSUS, which provides for Machines and mechanical appliances having individual functions, not specified or included elsewhere in this chapter; parts thereof: Other machines and mechanical appliances: Other: Other ...Other. The rate of duty will be 2.5 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/. 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. Sincerely, Robert B. Swierupski Director, National Commodity Specialist Division