# NY H81443

June 29, 2001

CLA-2-84:RR:NC:1:104 H81443

CATEGORY: Classification

TARIFF NO.: 8449.00.5000; 8422.30.90

Mr. Kent Sunakoda

James J. Boyle & Co.

2525 Corporate Place, #100

Monterey Park, CA 91754

RE: The tariff classification of thermal bonding lines for nonwoven
products from Korea.

Dear Mr. Sunakoda:

In your letter dated May 17, 2001 on behalf of SkyvivaUS Inc. of Los
Angeles, California you requested a tariff classification ruling.

Your client will be importing four thermal bonding lines for nonwovens,
two lines with needle punching and heat pressing machines and two lines
without. All machines contained in a manufacturing line will arrive on
the same vessel. The lines will consist of the following machines:

Lines with needle punch and heat press: Lines without:

1\. weighing feeder weighing feeder

2\. conveyor feeder conveyor feeder

3\. beak opener beak opener

4\. mixing hopper mixing hopper

5\. chute hopper & scale unit chute hopper & scale unit

6\. carding machine carding machine

7\. cross layer cross layer

8\. needle puncher thermal bonding oven

9\. thermal bonding oven cooler

10\. heat press side cutter & cross cutter

11\. cooler 2nd opener

12\. side cutter & cross cutter auto stacker

13\. 2nd opener auto packer

14\. auto stacker

15\. auto packer

The nonwoven product in this instance will be polyester insulation. The
raw material includes polyester staple fiber (PSF) and low melting fiber
(LMF). The first seven machines prepare the fibers leading to the
formation of a web of the desired thickness before the bonding process
begins. The lines incorporating needle punching and heat pressing in
addition to thermal bonding produce acoustical non-woven products that
are thinner and possess a more rigid texture than products made by the
lines without these machines.

The thermal bonding is accomplished by hot air circulation with the
product carried through the oven on a mesh belt conveyor. The needle
puncher is a mechanical bonding machine which produces fiber
entanglement. Mechanical bonding is often used as the initial stage of
bonding followed by thermal bonding to give additional properties. The
heat pressing adds strength and density to the product. After bonding,
the product is cooled, cut to size, stacked and then stuffed into a
plastic package and sealed by an auto packing machine.

The thermal bonding lines, with and without the needle puncher and heat
press, (but not including the auto packer) are classified as functional
units under subheading 8449.00.5000, Harmonized Tariff Schedule of the
United States (HTS), which provides for machinery for the manufacture of
felt or nonwovens in the piece or in shapes ...: other. The rate of duty
will be free.

The auto packing machines are classified separately under HTS subheading
8422.30.90 which provides for machinery for filling, closing, sealing or
labeling bottles, cans, boxes, bags or other containers: other. The rate
of duty will be free.

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 Robert Losche at 212-637-7038.

Sincerely,

Robert B. Swierupski

Director,

National Commodity

Specialist Division