The tariff classification of an automated lumber bundle formation system from Canada

N362842
July 29, 2026
CLA-2-84:OT:RR:NC:N1:103
CATEGORY: Classification
TARIFF NO.: 8428.90.0390
Kathleen McLaughlin A.N. Deringer 173 West Service Road Champlain, NY 12919 RE: The tariff classification of an automated lumber bundle formation system from Canada Dear Ms. McLaughlin: In your letter dated July 2, 2026, you requested a tariff classification ruling on behalf of your client, Machinage Piche Incorporated. The subject Automated Lumber Bundle Formation System is engineered to create lumber bundles. The lumber bundles are formed by an automated stacking machine that is positioned between upstream and downstream conveyors and other machines. Due to its overall size, the system will be imported as modules ready for assembly, with all modules imported in a single shipment. The first section consists of a series of conveyors referred to as two Haul Out Chain Modules, an Automated Lumber Distribution Module, and a Lumber Flow Accumulation Module. The Haul Out Chain Modules transport lumber from an upstream Sorter Module (not imported with the system) to the Automated Lumber Distribution Module, which is a chain-type conveyor mounted on a platform that moves horizontally on rails. This platform transfers lumber to the Lumber Flow Accumulation Module, a stationary chain-type conveyor that conveys the lumber to the Unscrambler. The Unscrambler arranges randomly accumulated lumber pieces into a parallel and evenly-spaced orientation, preparing them for downstream automated bundle-forming operations. This machine may be configured as a “single” or “double,” with the double configuration consisting of two single units stacked vertically, but otherwise identical in function. The next group of machines includes Speed Up Chains and Package Maker Accumulation Transfer Units, both specialized conveyors. The Speed Up Chains regulate the spacing, timing, and sequencing of lumber planks as they exit the Unscrambler. The Package Maker Accumulation Transfer Unit, a chain-type

conveyor, arranges the planks according to specified bundle dimensions. This is accomplished by adjusting conveyor speed and buffering planks into organized rows, which are then transferred to the Package Maker for bundle assembly. The Package Maker is the core of the automated bundle-forming system, responsible for aligning, stacking, and bundling the incoming rows of planks. Incorporated into this unit are two submodules: the Pressing Foot module, which secures planks in place during bundling, and the Secondary Lift module, located in the lower section of the Package Maker. The Secondary Lift module lowers the assembled bundles, enabling the Package Maker to continue stacking rows and maintain uninterrupted automated stacking cycles. The final group of machines includes an Outfeed Bundle Synchronization Module, Package Outfeed Rollers, a Strapping Machine, a Strapping Machine Infeed Roller, a Strapping Machine Outfeed Transfer, a Package Doubler, and an Outfeed Package Transfer. The Outfeed Bundle Synchronization Module, Package Outfeed Rollers, Strapping Machine Infeed Roller, Strapping Machine Outfeed Transfer, and Outfeed Package Transfer are all conveyors. The Strapping Machine straps the bundles before they are conveyed to the Package Doubler, which stacks the bundles for retrieval by a forklift operator. The system also incorporates a Makeup Deck and Re-entry Bundle Sequencing Module to handle rejected or reprocessed lumber. Both units are chain-type conveyors designed to transport and reintegrate rejected lumber back into the system. In accordance with Note 4 to Section XVI, Harmonized Tariff Schedule of the United States (HTSUS), we consider the subject Automated Lumber Bundle System with all of its interconnected modules to be a functional unit. The clearly defined function is the stacking of lumber planks into a bundle. The applicable subheading for the Automated Lumber Bundle Formation System will be 8428.90.0390, HTSUS, which provides for “Other lifting, handling, loading or unloading machinery (for example, elevators, escalators, conveyors, teleferics): Other machinery: Other.” The general rate of duty will be free. Merchandise is to be classified according to its condition as imported. Should the requirements of 19 CFR § 141.51 and 19 CFR § 141.58 not be met, each component of the system would be separately classified in its own respective heading. 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 at https://hts.usitc.gov/. This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the classification stated above, the merchandise covered by this ruling may also need to be reported with either the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions covering exceptions to such tariffs. For further information to assist with the importation process, please refer to the frequently updated Cargo Systems Messaging Service (CSMS) messages at https://www.cbp.gov/trade/automated/cargo-systems-messaging-service and the Trade Remedies page at https://www.cbp.gov/trade/programs-administration/trade-remedies. The holding set forth above applies only to the specific factual situation and merchandise description as identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations (CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and complete in every material respect. In the event that the facts are modified in any way, or if the goods do not

conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2. Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic verification by CBP. This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection 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, please contact National Import Specialist Paul Huang at [email protected].
Sincerely,
(for) James P. Forkan Director National Commodity Specialist Division