What Every Member of the 

Trade Community Should Know About: 

Soldering and 

Welding Machines 

and Apparatus 

AN INFORMED COMPLIANCE PUBLICATION 

AUGUST 2008 
Soldering and Welding Machines and Apparatus 

August 2008 

NOTICE:

This publication is intended to provide guidance and information to the trade community. 

It reflects the position on or interpretation of the applicable laws or regulations by U.S. 

Customs and Border Protection (CBP) as of the date of publication, which is shown on 

the front cover. It does not in any way replace or supersede those laws or regulations. 

Only the latest official version of the laws or regulations is authoritative. 

Publication History 

First Published: January 2000 

Revised April 2001 

Revised March 2004 

Reviewed with No Changes May 2005 

Reviewed with No Changes March 2006 

Revised August 2008 

PRINTING NOTE: 

This publication was designed for electronic distribution via the CBP website 

(http://www.cbp.gov) and is being distributed in a variety of formats. It was originally set 

up in Microsoft Word 2003®. Pagination and margins in downloaded versions may vary 

depending upon which word processor or printer you use. If you wish to maintain the 

original settings, you may wish to download the .pdf version, which can then be printed 

using the freely available Adobe Acrobat Reader®. 

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Soldering and Welding Machines and Apparatus 

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PREFACE 

On December 8, 1993, Title VI of the North American Free Trade Agreement Implementation 

Act (Pub. L. 103-182, 107 Stat. 2057), also known as the Customs Modernization or “Mod” Act, 

became effective. These provisions amended many sections of the Tariff Act of 1930 and 

related laws. 

Two new concepts that emerge from the Mod Act are “informed compliance” and “shared 

responsibility,” which are premised on the idea that in order to maximize voluntary compliance 

with laws and regulations of U.S. Customs and Border Protection, the trade community needs to 

be clearly and completely informed of its legal obligations. Accordingly, the Mod Act imposes a 

greater obligation on CBP to provide the public with improved information concerning the trade 

community's rights and responsibilities under customs regulations and related laws. In addition, 

both the trade and U.S. Customs and Border Protection share responsibility for carrying out 

these requirements. For example, under Section 484 of the Tariff Act, as amended (19 U.S.C. 

1484), the importer of record is responsible for using reasonable care to enter, classify and 

determine the value of imported merchandise and to provide any other information necessary to 

enable U.S. Customs and Border Protection to properly assess duties, collect accurate 

statistics, and determine whether other applicable legal requirements, if any, have been met. 

CBP is then responsible for fixing the final classification and value of the merchandise. An 

importer of record’s failure to exercise reasonable care could delay release of the merchandise 

and, in some cases, could result in the imposition of penalties. 

Regulations and Rulings (RR) of the Office of International Trade has been given a major role in 

meeting the informed compliance responsibilities of U.S. Customs and Border Protection. In 

order to provide information to the public, CBP has issued a series of informed compliance 

publications on new or revised requirements, regulations or procedures, and a variety of 

classification and valuation issues. 

This publication, prepared by the National Commodity Specialist Division of Regulations and 

Rulings is entitled “Soldering and Welding Machines and Apparatus”. It provides guidance 

regarding the classification of these items. We sincerely hope that this material, together with 

seminars and increased access to rulings of U.S. Customs and Border Protection, will help the 

trade community to improve voluntary compliance with customs laws and to understand the 

relevant administrative processes. 

The material in this publication is provided for general information purposes only. Because 

many complicated factors can be involved in customs issues, an importer may wish to obtain a 

ruling under Regulations of U.S. Customs and Border Protection, 19 C.F.R. Part 177, or to 

obtain advice from an expert who specializes in customs matters, for example, a licensed 

customs broker, attorney or consultant. 

Comments and suggestions are welcomed and should be addressed to the Executive Director, 

Regulations and Rulings, Office of International Trade, U.S. Customs and Border Protection, 

1300 Pennsylvania Avenue, NW, (Mint Annex), Washington, D.C. 20229. 

Sandra L. Bell 

Executive Director, Regulations and Rulings 

Office of International Trade 

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INTRODUCTION..........................................................................................7

SECTION AND CHAPTER NOTES.............................................................8

Section XVI Notes ........................................................................................................ 8

Parts............................................................................................................................. 9

Spare Parts ............................................................................................................. 11

Invoicing .................................................................................................................. 11

Composite and Multifunction Machines................................................................... 11

Functional Units....................................................................................................... 12

Chapter Notes ............................................................................................................ 14

The Headings............................................................................................................. 14

Heading 8468.......................................................................................................... 15

Heading 8515.......................................................................................................... 18

Parts..................................................................................................................... 27

Articles Excluded or Misclassified as Parts .......................................................... 28

MACHINES AND APPARATUS OFTEN MISCLASSIFIED UNDER 

HEADING 8468 OR HEADING 8515.........................................................28

ADDITIONAL INFORMATION...................................................................30

The Internet................................................................................................................ 30

Customs Regulations ................................................................................................. 30

Customs Bulletin ........................................................................................................ 30

Importing into the United States ................................................................................. 31

Informed Compliance Publications............................................................................. 31

Value Publications...................................................................................................... 32

“Your Comments are Important”................................................................................. 33

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INTRODUCTION 

Imports of SOLDERING, BRAZING and WELDING machines and apparatus and 

parts thereof under headings 8468 and 8515 have been under close scrutiny in 

recent years. Many classification errors have been found during the course of this 

review. The purpose of this publication is to provide classification guidance to 

eliminate these errors in the future. 

How does the industry define soldering, brazing and welding? 

The Welding Handbook, Eighth Edition, published by the American Welding 

Society (AWS), provides the following definitions: 

Soldering is defined as a group of joining processes that produce coalescence 

of materials by heating them to the soldering temperature and by using a filler metal 

(solder) having a liquidus not exceeding 840 degrees F (450 degrees C) and below the 

solidus of the base metals. The solder is distributed between closely fitted faying 

surfaces of the joint by capillary action. (A faying surface is that mating surface of a 

member that is in contact with or in close proximity to another member to which it is to 

be joined.) 

Brazing joins materials by heating them in the presence of a filler metal having a 

liquidus above 840 degrees F (450 degrees C) but below the solidus of the base metals. 

Welding is a joining process that produces coalescence of materials by heating 

to welding temperature with or without application of pressure or by application of 

pressure alone and with or without the use of filler metal. 

In addition to these general definitions, the definitions of specific processes (e.g., 

flux cored arc welding), appearing further on in this publication are all taken from the

Welding Handbook and the ASW publication A3.0-94, Standard Welding Terms and 

Definitions. 

Soldering, brazing and welding machinery and apparatus are provided for in the 

Harmonized Tariff Schedule of the United States (HTSUS) under headings 8468 and 

8515. Both headings include such machinery and apparatus whether or not capable 

of cutting; however, both exclude equipment designed exclusively for cutting. 

Neither heading includes accessories. The most basic distinction between the 

headings is that heading 8468 covers non-electrical equipment while heading 8515 

covers electrical equipment. 

There is a significant change from the classification of this equipment under the 

previous tariff, the Tariff Schedules of the United States Annotated (TSUSA). Under the 

TSUSA, welding, etc. was limited to metals. Under the HTSUS, there is no such 

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Soldering and Welding Machines and Apparatus 

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limitation under either heading 8468 or heading 8515. The Explanatory Notes (ENs) to 

both headings describe thermoplastic welding apparatus. 

CLASSIFICATION TOOLS 

Harmonized Tariff Schedule of the United States (HTSUS) – For legal 

purposes, soldering and welding machines and apparatus, as with all imported 

merchandise, are to be classified in accordance with the terms of the headings of the 

HTSUS, any relative section and chapter notes and, provided such headings or notes 

do not otherwise require, in accordance with the General Rules of Interpretation (GRIs) 

taken in order. 

Harmonized Commodity Description and Coding System Explanatory Notes

(ENs or Explanatory Notes)

1

 – These notes are the official interpretation of the 

Harmonized System (HS) at the international level. The ENs are not dispositive nor are 

they legally binding. However, they do provide commentary on the scope of each 

heading of the Harmonized System. [See T.D. 89-80, published in the Federal Register

on August 23, 1989 (54 Fed. Reg. 35127, 35128).] 

SECTION AND CHAPTER NOTES 

Before proceeding to discuss these headings, it is necessary to examine the 

relevant section and chapter notes and to read the General Rules of Interpretation 

(GRIs) and the Additional U.S. Rules of Interpretation. GRI 1 provides that for legal 

purposes, classification shall be determined according to the terms of the headings (in 

this case, heading 8468 and heading 8515) and any relative section or chapter notes. 

In the event that the goods cannot be classified solely on the basis of GRI 1, and if the 

headings and legal notes do not otherwise require, the remaining GRIs 2 through 6 may 

then be applied in order. Both headings are found in section XVI, which includes, 

among other things, machinery, mechanical equipment, and electrical equipment. 

Notes 1(a) through (q) of section XVI describe items not covered by the section. These 

items cannot be classified under chapter 84 (which includes the non-electrical soldering, 

brazing and welding equipment) or under chapter 85 (which covers the electrical 

equipment). 

Section XVI Notes 

Although all the notes should be read, for the purposes of this publication, 

comments will be made only on those notes most likely to affect the classification of 

soldering, brazing and welding apparatus. For example, note 1(b) will not be discussed 

because it excludes articles of leather. (If there are any parts for welding machines 

made of leather, we are unaware of them.) Notes that are more relevant include: 

 

1 The World Customs Organization (formerly the Customs Co-Operation Council) published the Fourth Edition (current) of the Harmonized 

Commodity Description and Coding System Explanatory Notes in 2007. 

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Note 1(a) excludes transmission, conveyor or elevator belts or belting, of plastics 

of chapter 39, or of vulcanized rubber (heading 4010); or other articles of a kind used in 

machinery or mechanical or electrical appliances or for other technical uses, of 

vulcanized rubber other than hard rubber (heading 4016). 

Note 1(c) excludes bobbins, spools, cops, cones, cores, reels or similar supports, 

of any material (for example, chapter 39, 40, 44 or 48 or section XV). Reels for welding 

wire have been erroneously entered as parts of welding machines and apparatus. 

Note 1(e) excludes transmission or conveyor belts of textile material (heading 

5910) or other article of textile material for technical uses (heading 5911). 

Note 1(g) excludes parts of general use, as defined in note 2 to section XV, of 

base metal (section XV), or similar goods of plastics (chapter 39). This note refers to 

items such as nuts, bolts, screws, springs, tube or pipe fittings, chains, etc. 

Note 1(k) excludes articles of chapter 82 or 83. For example, self-contained blow 

torches of subheading 8205.60 and coated electrodes of base metal, for electric arcwelding of heading 8311 are excluded. 

Note 1(m) excludes articles of chapter 90. Items such as measuring instruments 

(found in various headings in chapter 90, depending on the type) and separately 

imported lasers (subheading 9013.20) would be excluded. 

Parts 

The rules for classifying parts are provided for in section XVI, note 2, subject, of 

course, to the exclusions already mentioned in section XVI, note 1. 

Note 2(a) indicates that parts which are goods included in any of the headings of 

chapter 84 or chapter 85 are in all cases to be classified in their respective headings. 

The ENs to Section XVI provide numerous examples of such parts and state that the 

classification applies even if the part is specially designed to work as part of a specific 

machine. Examples include: 

pumps - heading 8413 

lifting and handling machinery - heading 8428 

valves - heading 8481 

bearings - heading 8482 

gearboxes - heading 8483 

electric motors - heading 8501 

welding generators - heading 8502 

welding transformers - heading 8504 

welding control panels - heading 8537 

welding cables - heading 8544 

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Note also that a part of one of the above items which is, in turn, part of a welder 

will be classified as a part of that item, not as a part of the welder. For example, a part 

of a motor for a welding machine would be classified as a part of the motor, not as a 

part of the welder, subject of course to any section or chapter notes or heading 

requirements for motors and parts thereof. 

Note 2(b) states essentially that other parts, if suitable for use solely or principally 

with a particular kind of machine, or with a number of machines of the same heading, 

are to be classified with the machines of that kind. This means that a part of a welder, 

for example, that is not excluded by note 1 (such as a laser) or note 2(a) (such as a 

power supply) would be classified under subheading 8468.90 if part of a non-electric 

welder or under subheading 8515.90 if part of an electric welder. 

As you can see, the note refers to other “parts” and not to “accessories.” The 

individual headings themselves, heading 8468 and heading 8515, do not include 

accessories. (Some headings in chapter 84, however, do include accessories. For 

example, heading 8466 provides for parts and accessories suitable for use solely or 

principally with machine tools.) The distinction between “parts” and “accessories” can 

be difficult. Some items, such as electrode holders, which are described as parts in the 

ENs to heading 8515, are often described in welding catalogs as accessories. 

An item is more likely to be classified as other parts under note 2(b) if it is 

essential to the operation of the machine or apparatus it is used with. Other factors to 

be considered include dedication to use with a particular individual machine or type of 

machine or apparatus (i.e., is the item solely or principally used with the machine?). 

Can the item be used with any other type of machinery? Does the item participate in 

the operation of the machine? Or is it merely used offline? 

The “essential” factor can be subject to interpretation. For example, many 

welding processes involve feeding in wire. Is the wire feeder essential? Theoretically, 

someone could stand by and manually feed wire into the weld pool. As a practical 

matter, the wire feeder is often essential to the efficient operation of the machine. For 

this reason, it is classified as a “part”. The electrode holder obviously participates in the 

process as it holds the electrode during the welding operation. 

Many welding processes require the use of jigs and fixtures. The function of a 

fixture is to facilitate assembly of parts and to hold the parts in a fixed relationship 

during the weld. (In engineering, the terms jig and fixture have essentially the same 

meaning.) 

Items not essential or dedicated to the machine or apparatus are not likely to be 

classified as parts. A stand to hold the soldering iron when not in use is not essential to 

the soldering process. It does not hold the iron when in use. A solder tip cleaner, a 

device used to remove debris from the soldering tip, likewise does not participate in the 

soldering operation. These items are accessories. 

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In general, consumables are not classified as parts. Such items include but are 

not limited to consumable electrodes, welding wire, solder paste, gas for gas welding 

processes, etc. 

If classification as “parts” is claimed, the importer may be asked to provide 

literature on the welding machine or apparatus that the item is said to be a part of and 

indicate where the part is, what its function is, etc. 

At the end of this publication, a list of items related to welding is provided, 

indicating which items are parts and which are classified elsewhere. 

Spare Parts 

What about spare parts? Example: A foreign manufacturer ships a welding 

machine with a few extra bearings, gears, valves, switches, etc. because these items 

require replacement more frequently than other components. 

Spare parts cannot be classified with the machine. They must be separately 

classified in accordance with the relevant section or chapter notes. 

Invoicing 

Example: The invoice from the manufacturer lists the basic machine followed by 

the specific options ordered as follows: 

plasma arc welder model A 

DC power source model B 

control console model C 

Are the power source and control separately classified? The invoice may or may not 

have unit values for each item listed. 

As long as the invoiced items constitute one machine, they are classified under 

the appropriate heading for that machine. If it is not apparent from the invoice that it is a 

single machine (or more than one complete machine), CBP may question classification 

under a single tariff provision. It would be helpful if the invoice would state, for example, 

“plasma arc welder, including model B power source ... .” etc. 

Composite and Multifunction Machines 

Section XVI, note 3 deals with composite machines, which are defined as two or 

more machines fitted together to form a whole and other machines adapted to perform 

two or more complementary or alternative functions. Classification is to be determined 

as if consisting only of that component or as being that machine which performs the 

principal function. 

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The ENs to Section XVI indicate that a machine is taken to be “fitted together to 

form a whole” when incorporated one in the other or mounted one on the other, or 

mounted on a common base or frame or in a common housing. 

A combination welding and cutting machine mounted on a common base, for 

example, would be classified as a welding machine if welding is the principal function. If 

that composite welding/cutting machine, which normally would incorporate a control 

unit, were to be imported without the control, it would still be classified as a welding 

machine because GRI (General Rule of Interpretation) 2(a) indicates that any reference 

in a heading to an article shall be taken to include a reference to that article incomplete 

or unfinished, provided that, as entered, the incomplete or unfinished article has the 

essential character of the complete or finished article. 

Functional Units 

Section XVI, note 4 deals with the functional unit concept. Where a machine 

(including a combination of machines) consists of individual components (whether 

separate or interconnected by piping, cables, etc.) intended to contribute together to a 

clearly defined function covered by one of the headings in chapter 84 or chapter 85, 

then the whole falls to be classified in the heading appropriate to that function. 

A common example of the functional unit in the welding industry is the robot with 

welding attachment connected to a control panel by electrical cables. The welding 

attachment, also known as “end of arm tooling”, may be a resistance welding package 

for spot welding or an arc welding package. The robot manipulates the welding torch as 

directed by the controller. In most instances, the robot and control unit is imported 

without this end of arm tooling. Headquarters (HQ) ruling 965638, dated July 16, 2002, 

addresses the classification of welding and material handling robots imported without 

welding guns, grippers or other end-of-arm tooling. 

In HQ 965638, the robot systems at issue consisted of an articulated arm or 

manipulator on a base, a controller and a programming or teaching pendant. Prior to 

importation, each robot is “configured,” that is, a program of instructions to implement 

the robot’s intended end use (welding, material handling, etc.) is burned onto a chip that 

becomes part of the controller, which is stand-alone and connected to the manipulator 

by electrical wiring or cables. The programming pendant is hand-held and attached by 

cable to the controller. It functions as an input device that sends operating instructions 

in the form of signals which the controller interprets and uses to instruct the manipulator. 

 The ruling determined that under the authority of GRI 2(a) and Section XVI, Note 

4, HTSUS, an articulated arm or manipulator imported with its configured process 

controller and programming pendant, constitutes a functional unit provided for in 

heading 8515 or heading 8428 (depending on how it’s configured) even when imported 

without the end-of-arm tooling. The end-of-arm tooling represents a rather small 

percentage of the total value of the completed robot. The fact that the robot is 

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permanently configured for a particular application by a chip installed in the controller is 

sufficient to establish the essential character of the goods. 

Another example of a functional unit is a welded tube forming line. Although not 

classified as welding machinery and apparatus, it does include welding equipment, 

which would be classified under heading 8515 if separately imported. In such a line, 

usually referred to as a welded tube mill, we have handling devices, machine tools and 

welding equipment contributing to the production of a welded tube. Welded tube mills 

have often been mistakenly entered as rolling mills of heading 8455. 

 A welded tube mill essentially takes coiled metal strip, passes it through a series 

of bending rolls which gradually form it into a cylindrical tube, welds the seam to close 

the tube, sizes the welded tube, and cuts it off to the desired length. HQ rulings 

965198, dated May 1, 2002, 229216, dated May 21, 2002, and 965296, dated July 9, 

2002, classified these welded tube mills as functional units under subheading 8462.29 

(or 8462.21 if numerically-controlled) as machine tools for bending metal. By 

application of note 4 to Section XVI, it was concluded that the function of the welded 

tube mill is essentially a metal forming operation which involves a bending of the metal 

to impart a cylindrical curve to the metal sheet to form a tube. 

Machinery lines of this type are often imported in a number of shipments due to 

size considerations. Prior to July 3, 2006, the functional unit concept could not be 

applied if there was more than one shipment involved. Historically, for classification 

purposes, each shipment stands on its own. In HQ ruling 958807 of April 30, 1996, it is 

stated that “It is well settled that merchandise must be classified and assessed duty in 

condition as imported. Components of a machine that arrive within the customs territory 

on different days cannot be aggregated for classification and appraisement purposes 

under a single HTSUS provision.” 

Effective July 3, 2006, new regulations were implemented allowing an importer of 

record, under certain conditions, to submit a single entry to cover multiple portions of a 

single entity which, due to its size or nature, arrives in the United States on separate 

conveyances. 19 C.F.R. Section 141.58 sets forth, in detail, the requirements to be met 

in order for the shipments to qualify under the “single entry” concept. See also Section 

1460 of Public Law 106-476 a/k/a “Tariff Suspension and Trade Act of 2000”; 19 U.S.C 

1484(i)(1); Customs Bulletin and Decisions, Vol. 40, No. 25, June 14, 2006, Pages 1-18; 

Federal Register, Vol. 71, No. 106, June 2, 2006, Pages 31921-31927. 

A wire mesh making machine was classified under subheading 8515.21 in New 

York (NY) ruling B82366, dated March 3, 1997. Another example of a functional unit, it 

consisted essentially of an uncoiler, straightener, shear, positioner, welder, stacker and 

output conveyor. 

Generally, any welding machine imported with a handling (loading, unloading, 

etc.) machine would be classified together as a functional unit under heading 8468 or 

heading 8515. The handling function of heading 8428 is always subsidiary. 

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Chapter Notes 

In addition to these section notes, we have the notes for the chapters within 

section XVI. 

For example, Chapter 84, note 1(b) excludes ceramic articles. A ceramic part of 

a non-electric welder of heading 8468 must be classified under chapter 69. However, a 

ceramic part for an electric welder of heading 8515 (such as a ceramic nozzle) would be 

classified in subheading 8515.90 because chapter 85 does not have a note excluding 

ceramic articles. 

Chapter 84, note 2 states that “Subject to the operation of Note 3 to Section XVI 

and subject to Note 9 to this chapter, a machine or appliance which answers to a 

description in one or more of the headings 8401 to 8424, or heading 8486 and at the 

same time to a description in one or more of the headings 8425 to 8480 is to be 

classified under the appropriate heading of the former group or under heading 8486, as 

the case may be, and not the latter group.” 

Heading 8515, in addition to soldering, brazing or welding machines, includes 

“electric machines and apparatus for hot spraying of metals or cermets.” Heading 8468 

does not include such “spraying” apparatus because of chapter 84, note 2. Heading 

8424 includes mechanical appliances for projecting, dispersing or spraying liquids or 

powders. The ENs to heading 8424 mention that metal spraying pistols are covered 

under that heading, which provides for spray guns and similar appliances (subheading 

8424.20.90). Chapter 84, note 2, as indicated above, would require classification under 

heading 8424 because heading 8424 is in the former group of headings. 

Note 2 begins “[s]ubject to Note 3 to Section XVI,” which deals with composite or 

multifunction machines. If a machine of this type performed the non-electric hot 

spraying function of heading 8424 and, for example, oxyfuel welding of heading 8468, 

the principal function would have to be determined before applying chapter 84, note 2. 

If welding were the principal function, the spraying function would not be considered. 

The Headings 

Now that we have reviewed the legal notes and understand them fully, the 

classification of the machines may appear to be simple. Heading 8468 covers nonelectrical equipment and heading 8515 covers electrical equipment. However, the 

invoice descriptions are often inadequate and industry terms can be less than 

illuminating, at least for tariff purposes. Classification at the subheading level involves a 

more thorough analysis. 

Example: The invoice submitted to Customs and Border Protection(CBP) reads 

“Stud Welder.” Stud welding is a general term for joining a metal stud or similar part to 

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a workpiece. It can be done by arc welding (subheading 8515.31), resistance welding 

(subheading 8515.21), friction welding (subheading 8468.80), etc. 

Example: The invoice submitted to CBP reads “Spot Welder.” While most spot 

welders are resistance welders (subheading 8515.21), the function can also be 

performed by arc welding (subheading 8515.31) or other methods. 

First let us address heading 8468. In the course of reviewing entries under the 

Multi-port Approach to Raise Compliance (MARC 2000) program, it was discovered that 

MOST of the equipment entered under heading 8468 actually belonged in heading 8515 

as well as some other headings. This result is not that surprising because most of the 

welding equipment in use today is electrical. 

Heading 8468 

Heading 8468 provides as follows: 

8468 Machinery and apparatus for soldering, brazing or welding, whether 

or not capable of cutting, other than those of heading 8515; 

gas-operated surface tempering machines and appliances; parts 

thereof: 

8468.10.00 00 Hand-held blow torches 

8468.20 Other gas-operated machinery and apparatus: 

8468.20.10 00 Hand-directed or -controlled 

8468.20.50 00 Other 

8468.80 Other machinery and apparatus: 

8468.80.10 00 Hand-directed or -controlled 

8468.80.50 00 Other 

8468.90 Parts: 

8468.90.10 00 Of hand-directed or –controlled machinery and 

apparatus 

8468.90.50 00 Other 

As stated in the heading, apparatus other than those of heading 8515 fall within 

heading 8468. The ENs to heading 8468 indicate that the heading excludes welding, 

brazing or soldering machines and apparatus using both gas and electricity. 

In the section for gas operated appliances for working metal, etc., the heading 

8468 ENs state that the appliances of this group are operated by means of a very hot 

flame produced by the combustion of an inflammable gas in a jet of oxygen or air. 

Further on, the ENs state that ALL the appliances of this group have an arrangement for 

bringing two gases to the nozzle which has two outlets, either concentric or side by side; 

one of the gases is inflammable (acetylene, butane, propane, etc.) and the other gas is 

compressed air or oxygen. 

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Subheading 8468.10 provides for: 

Hand-held blow torches – The ENs to heading 8468 refer to “blowpipes”, 

describing them as high pressure or low pressure, and indicating that both types are of 

similar construction. They consist of a handle or body fitted with the supply pipes, at the 

exit of which (i.e., the nozzle) the gas is ignited. They generally also include regulating 

valves. The apparatus is connected to an external gas supply by flexible tubing. 

The description of blow torches in the ENs appears to describe an oxyfuel gas 

process. Oxyfuel gas welding is a term used to describe any welding process that uses 

a fuel gas combined with oxygen to produce a flame having sufficient energy to melt the 

base metal. The fuel gas (normally acetylene) and oxygen are mixed in the proper 

proportions in a chamber which is generally a part of the welding torch assembly. 

Basic oxyfuel welding equipment consists of fuel gas and oxygen cylinders, each 

with a gas regulator, hoses for conveying the gases to the torch, and a torch and tip 

combination for adjusting the gas mixtures and producing the desired flame. A typical 

welding torch consists of a torch handle with control valves, mixer and tip assembly. In 

the mixer, the oxygen enters a center duct while the fuel gases enter angled ducts to 

effect the mixing. The welding tip is that portion of the torch through which the gases 

pass just prior to ignition and burning. 

Subheading 8205.60 provides for blow torches and similar self-contained 

torches. The ENs to heading 8205 refer to “blow lamps“ (e.g., for soldering or brazing; 

for paint removal; for starting diesel engines) of two types, which differ in the type of fuel 

used, incorporating either (1) a fuel reservoir for mineral oil or other liquid fuel or (2) a 

replaceable gas cartridge. Both types are self-contained, however. The heading does 

not cover gas operated welding appliances. 

The major difference between the subheadings is that the blow torches of 

heading 8468 are connected to an external gas supply while those of heading 8205 are 

self-contained blow torches and blow torches of heading 8468 must have the 

arrangement for bringing two gases to the nozzle. 

Most of the blow torches of subheading 8468.10 are used in the jewelry industry. 

Some blow torches are also used in dental labs. (See NY ruling C87628 of May 21, 

1998). The blow torches of subheading 8205.60 may be marketed for soldering, but 

many are promoted as multipurpose piezoelectric devices, and list applications such as 

burning wood, lighting campfires, waxing skis, thawing frozen locks, sterilizing needles, 

and functioning as a portable torch. 

 

Subheading 8468.20 provides for: 

Other GAS operated machinery and apparatus – Thus the subheading covers 

gas operated machinery and apparatus other than blow torches. At the 8-digit level, the 

subheading identifies: 

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August 2008 

8468.20.10 - Hand-directed or -controlled 

8468.20.50 - Other 

The ENs to heading 8468 indicate that all hand-operated gas appliances of 

heading 8468 are connected to an external gas supply. Oxyfuel processes are primarily 

manual and most hand directed torches employing an oxyfuel process are the blow 

torches of subheading 8468.10. It does not appear that there should be much trade in 

subheading 8468.20.10. 

The subheading also covers gas-operated surface tempering machines and 

appliances, which would fall under subheading 8468.20.50. The heading 8468 ENs 

indicate that these consist of a number of nozzles arranged according to the shape of 

the object to be treated. The flames from these nozzles project onto the surface to be 

tempered a heat of such intensity that it is rapidly brought to the temperature required, 

but this heat does not penetrate far below the surface. Once the surface has been 

brought to the required tempering temperature, sprays of cooling liquid are directed on 

the article or it is immersed in a bath of the liquid. 

Subheading 8468.80 provides for: 

Other machinery and apparatus – 

Subheading 8468.80.10 - hand-directed or -controlled 

Subheading 8468.80.50 - other 

The main types of non-electric welders, other than the gas operated type of subheading 

8468.10 and subheading 8468.20, include: 

Friction Welding (FRW) – defined as a solid-state welding process that 

produces a weld under compressive force contact of workpieces rotating or moving 

relative to one another to produce heat and plastically displace material from the faying 

surfaces. 

Example - spin welder for thermoplastic pipe (NY ruling D84150, dated 

November 19, 1998) 

Diffusion Welding (DFW) - a solid state welding process that produces a weld 

by the application of pressure at elevated temperature with no macroscopic deformation 

or relative motion of the workpieces. A filler metal may be inserted between the faying 

surfaces. 

Cold Welding - a solid state process in which pressure is used at room 

temperature to produce coalescence of metals with substantial deformation at 

the weld. A characteristic of the process is the absence of heat, either applied 

17
Soldering and Welding Machines and Apparatus 

August 2008 

externally or generated by the welding process itself. (Cold welding is perhaps 

the only truly nonthermal welding process.) 

Subheading 8468.90 provides for: 

 Parts – 

 

Subheading 8468.90.1000 - of hand-directed or –controlled machinery 

and Apparatus 

 Subheading 8468.90.5000 - other 

Subheading 8468.90.10 provides for parts of hand-directed or - controlled 

machinery and apparatus. 

Examples: needles for blow torch (for micro-fine soldering) 

mixer for a welding torch 

Subheading 8468.90.50 provides for other - parts of other than hand-directed or 

– controlled machinery and apparatus. 

Example: bases, frames, etc. for a welding machine 

Heading 8515 

 Before discussing heading 8515, it should be noted that, effective February 3, 

2007, changes to the HTSUS resulted in the migration of certain Information 

Technology Products from various chapters of the HTSUS to one central HTSUS 

provision, i.e., heading 8486. On December 13, 1996, the Information Technology 

Agreement (ITA) was signed. Presidential Proclamation 7011 (reflecting the provisions 

of the World Trade Organization Ministerial Declaration on Trade in Information 

Technology Products), dated July 1 1997, contained the details necessary to implement 

the tariff concessions granted by this Agreement. Included in the scope of the products 

eligible for duty-free treatment under the ITA was welding equipment used in the 

assembly of semiconductor devices. Provisions were made in heading 8515 for this 

merchandise. While various changes had been made to the language of the 

subheadings of heading 8515, in the intervening years, the merchandise continued to 

be classified in heading 8515. Now, with the implementation of the HTSUS provisions 

on February 3, 2007, this type of welding equipment (and its parts) is classified in 

heading 8486, which provides for machines and apparatus of a kind used solely or 

principally for the manufacture of semiconductor boules or wafers, semiconductor 

devices, electronic integrated circuits or flat panel displays; machines and apparatus 

specified in note 9(C) to chapter 84; parts and accessories. 

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Soldering and Welding Machines and Apparatus 

August 2008 

Heading 8515 provides as follows: 

8515 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: 

8515.11.00 00 Soldering irons and guns 

8515.19.00 00 Other 

Machines and apparatus for resistance welding of metal: 

8515.21.00 00 Fully or partly automatic 

8515.29.00 00 Other 

 Machines and apparatus for arc (including plasma arc) 

welding of metals: 

8515.31.00 00 Fully or partly automatic 

8515.39.00 Other 

Non-rotating type: 

 20 AC transformer type 

 40 Other 

 60 Rotating type 

8515.80.00 Other machines and apparatus 

 40 Ultrasonic welding machines 

 80 Other 

8515.90 Parts: 

8515.90.20 00 Of welding machines and apparatus 

8515.90.40 00 Other parts 

Subheadings 8515.11 and 19 provide for: 

Brazing or soldering machines and apparatus 

The ENs to heading 8515 indicate that only machines and apparatus which by 

means of their special attachments (for example, a system of feeding in solder wire) are 

identifiable as solely or principally intended for brazing or soldering belong to this group. 

They indicate that the heading also covers electrically heated hand soldering irons and 

guns. 

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Soldering and Welding Machines and Apparatus 

August 2008 

Subheading 8515.11 provides for: 

Soldering irons and guns 

The traditional soldering tool is the soldering iron with a copper tip. These tools 

are generally resistance heated. In fact, most soldering today is electrical. (As noted 

earlier, torch or gas soldering of heading 8468 is mainly limited to the jewelry industry 

and dental labs.) 

The subheading also includes desoldering irons, which may or may not 

incorporate a pump, to remove the melted solder. 

Subheading 8515.19 provides for: 

 “Other” (covering soldering machines and apparatus other than soldering irons 

and guns as well as brazing machines and apparatus) 

Examples of the equipment covered by this subheading include: 

Soldering/Desoldering Stations - including a soldering gun with a control unit 

(known as rework stations - see NY ruling 838921, dated April 13, 1989) for removing 

and replacing surface mount components from printed circuit boards (PCBs). It may 

also include a wire feeder. 

In addition to soldering irons and guns, rework stations, etc. there is some 

specialized soldering equipment for the PCB industry. This equipment includes: 

Wave Solder Machines - automatic soldering systems used to attach throughhole technology electrical components to their printed wiring board. The solder is 

pumped out of a narrow slot above the solder pot to produce a wave or a series of 

waves. 

However, the following related equipment for PCBs is NOT classified under this 

subheading: 

Solder Reflow Ovens - specialized ovens through which PCBs are automatically 

passed following component placement. Classification is under subheading 8514.30. 

Hot Air Solder Levelers (HASL) - horizontal or vertical coaters used to apply 

molten solder to one or both sides of a PCB. Units include hot air blowoffs to level the 

solder. It is a coating, not a joining process, hence heading 8515 does not apply. 

Horizontal (spray) coaters (also known as curtain coaters) are classified in heading 

8424; vertical (dipping - the PCB is dipped into a solder pot) coaters are classified in 

heading 8479. 

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Soldering and Welding Machines and Apparatus 

August 2008 

Spray Fluxers - fluxing prepares the surfaces to be joined by cleaning the 

surface and protecting it from oxidation. Classification is under heading 8424. Note 

that some wave soldering machines incorporate a fluxing station. This is another 

example of a composite and multifunction machine. In this combination, wave soldering 

is the principal function, hence classification is under subheading 8515.19. 

Solder Paste Screen Printers - employ the same technology as any other 

screen printing machine. Classification is under subheading 8443.32.1090. 

Subheadings 8515.21 and 29 provide for: 

Machines and apparatus for resistance welding of metal 

Subheading 8515.21 covers apparatus which are fully or partly automatic. 

Subheading 8515.29 covers other than fully or partly automatic apparatus. 

In a fully automatic system, the workpiece is automatically fed, welded and 

ejected. 

In a partly automatic setup, the operator positions the workpiece or welding gun 

and pushes a switch to initiate the weld. 

A resistance welding machine has three principal elements: 

(1) an electrical circuit consisting of a welding transformer and a secondary 

circuit with electrodes that conduct the current to the work; 

(2) a mechanical system consisting of a machine frame and associated 

mechanisms to hold the work and apply the welding force; and 

(3) the control equipment to initiate and time the duration of current, which also 

may control the current magnitude as well as sequence and time of other parts of 

the welding cycle. 

The most common resistance welding processes include: 

Spot Welding (RSW) - most spot welders are of the resistance type. Produces 

coalescence at the faying surfaces of a joint by the heat obtained from resistance to the 

flow of welding current through the workpieces from electrodes that serve to 

concentrate the welding current and pressure at the weld area. 

Projection Welding (PW) - produces coalescence of materials by the heat 

obtained from the resistance to the flow of the welding current. The resulting welds are 

localized at predetermined points by projections, embossments, or intersections. 

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Soldering and Welding Machines and Apparatus 

August 2008 

Seam Welding (RSEW) - produces coalescence at the faying surfaces of 

overlapped parts progressively along a length of a joint. 

Flash Welding (FW) - a resistance welding process that produces a weld at the 

faying surfaces of a butt joint by a flashing action and by the application of pressure 

after heating is substantially completed. 

Upset Welding (UW) - a resistance welding process that produces coalescence 

over the entire area of faying surfaces, or progressively along a butt joint, by the heat 

obtained from the resistance to the flow of welding current through the area where those 

surfaces are in contact. Pressure is used to complete the weld. 

Subheadings 8515.31 and 39 provide for: 

Machines and apparatus for arc (including plasma arc) welding of metals 

Subheading 8515.31 covers apparatus which are fully or partly automatic. 

Subheading 8515.39 covers other than fully or partly automatic apparatus. 

The statistical suffixes under subheading 8515.39 refer to the power source; 

however, the welding head or gun still must be included to be classified in this 

subheading. 

Non-rotating type 

20 AC transformer type 

40 other 

60 Rotating type 

There are two types of rotating machinery: generators which produce direct 

current and alternators which produce alternating current. Both have a rotating member 

called a rotor or armature and a stationary member called a stator. 

The term arc welding applies to a large and diversified group of welding 

processes that use an electric arc as the source of heat to melt and join metals. The 

process may or may not require the use of filler metal. The welding arc is struck 

between the workpiece and the tip of an electrode. The electrode will either be a 

consumable wire or rod or a nonconsumable carbon or tungsten rod which carries the 

welding current. When a nonconsumable electrode is used, filler metal can be supplied 

by a spare rod or wire if needed. A consumable electrode, however, will be designed 

not only to conduct the current that sustains the arc, but also to melt and supply filler 

metal to the joint. 

In an automated setup, classified in subheading 8515.31, the equipment may 

include a controller, workpiece positioner and wire feeder, in addition to the welding 

machine or robot with welding attachments. 

22
Soldering and Welding Machines and Apparatus 

August 2008 

In a manual setup, classified in subheading 8515.39, the equipment generally 

consists of the torch or gun, welding cable and power supply, hoses and source of 

shielding gas. The torch may have auxiliary switches and valves built into the handle 

for controlling current and gas flow. The torch imported without the power supply or 

cable remains classified here as arc welding apparatus; it is not classified as parts. 

There have been many instances where welding power supplies have been 

classified under subheading 8515.31 or subheading 8515.39 as arc welders or 

subheading 8515.90 as parts. As noted above, subheading 8515.39 includes a 

statistical breakout for AC transformer type arc welders. This breakout may be the 

basis for some of the misclassifications. The ENs to heading 8515 indicate that 

separately imported welding generators are classified in heading 8502 while 

transformers and inverters fall under heading 8504. The ENs to heading 8502 and 

heading 8504 refer these products to classification in heading 8515 if imported with their 

welding heads. (See also HQ ruling 956586, dated October 4, 1994, which classified an 

inverter for a welding machine under subheading 8504.40.) 

The most common arc welding processes include: 

Shielded Metal Arc Welding (SMAW) - most widely used arc welding process in 

which coalescence of metals is produced by heat from an electric arc that is maintained 

between the tip of a covered electrode and the surface of the base metal in the joint 

being welded. The intense heat of the arc melts the tip of the electrode. In this manner, 

filler metal is deposited as the electrode is progressively consumed. 

Submerged Arc Welding (SAW) - produces coalescence of metals by heating 

them with an arc between a bare metal electrode and the work. The arc and molten 

metal are “submerged “ in a blanket of granular fusible flux on the work. 

Gas Metal Arc Welding (GMAW) - uses an arc between a continuous 

consumable filler metal electrode and the weld pool. May use a tubular electrode 

wherein metallic powders make up the bulk of the core materials (metal cored 

electrode). It has been the predominant choice for robotics. 

Flux Cored Arc Welding (FCAW) - uses an arc between a continuous filler 

metal electrode and the weld pool. The flux-cored electrode is a composite filler metal 

electrode consisting of a metal sheath and a core of various powdered materials. 

Gas Tungsten Arc Welding (GTAW) - uses an arc between a non-consumable 

tungsten electrode and the weld pool. The electrode extends beyond the end of the 

shielding gas nozzle. The process is used with shielding gas, without the application of 

pressure and with or without filler metal. 

Plasma Arc Welding (PAW) - produces coalescence of metals by heating them 

with a constricted arc between an electrode and the workpiece or between the electrode 

and the constricting nozzle. Pressure is not applied, and filler metal may or may not be 

23
Soldering and Welding Machines and Apparatus 

August 2008 

added. The process uses a non-consumable electrode; the electrode is recessed and 

does not touch the workpiece. The PAW torch has a nozzle that creates a gas chamber 

surrounding the electrode. The arc heats the gas fed into the chamber to a temperature 

where it becomes ionized and conducts electricity. This ionized gas is defined as 

plasma. 

Electro Gas Welding (EGW) - uses an arc between a continuous filler metal 

electrode and the weld pool, employing vertical position welding with backing to confine 

the molten weld metal. The process uses a consumable electrode, either solid or flux 

cored. The process is used with or without shielding gas and without the application of 

pressure. 

Electro Slag Welding (ESW) - produces coalescence of metals with molten slag 

that melts the filler metal and the surfaces of the workpieces to be welded. The process 

is initiated by an arc that heats a granulated flux and melts it to form the slag. 

Percussion Welding (PEW) - a joining process that produces coalescence with 

an arc resulting from a rapid discharge of electrical energy. Pressure is applied 

percussively during or immediately following the electrical discharge. 

Subheading 8515.80 provides for: 

“Other” (other than soldering, brazing, resistance welding and arc welding) 

Subheading 8515.80.0040 – “ultrasonic welding machines” - the parts to 

be joined are held together and subjected to ultrasonic vibrations. 

Subheading 8515.80.0080 – “other” (which includes other welding 

processes such as laser or other light or photon beam, magnetic pulse, thermoplastic 

welding as well as the electric machines and apparatus for hot spraying of metals or 

cermets). 

Electron Beam Welding (EBW) - a fusion process that produces coalescence of 

materials with heat obtained by impinging a beam composed primarily of high energy 

electrons onto the joint to be welded. The heart of the process is the electron beam 

gun/column assembly. 

Laser Beam Welding (LBW) - a fusion joining process that produces 

coalescence of materials with the heat obtained from a concentrated beam of coherent, 

monochromatic light impinging on the joint to be welded. It is a noncontact process, 

and thus requires that no pressure be applied. The most common types used are the 

YAG laser and the CO2 laser. (LASER is an acronym for Light Amplification by 

Stimulated Emission of Radiation.) 

One of the most common classification errors found is where separately imported 

lasers are classified under subheading 8515.80 as other electrical welding apparatus or 

24
Soldering and Welding Machines and Apparatus 

August 2008 

under subheading 8515.90 as parts. Section XVI, note 1(m) excludes articles of 

chapter 90. 

The ENs to heading 9013 indicate that, in addition to the lasing medium (e.g., the 

gas), the energy source (pumping system) and the resonant optical cavity (i.e., the 

basic elements combined in the laser head), lasers generally also incorporate a power 

supply, a cooling unit and a control unit. If these units are presented together, they 

remain in subheading 9013.20. They are excluded from heading 9013 if presented with 

work tables, work holders and means of feeding and positioning workpieces. 

Thermal Spraying (THSP) is a process in which a metallic or nonmetallic 

material is heated and then propelled in atomized form onto a substrate. The material 

may be initially in the form of wire, rod or powder. It is heated to the plastic or molten 

state by an oxyfuel gas or an electric or plasma arc. Arc or plasma arc spraying 

apparatus is classified in subheading 8515.80. Oxyfuel gas spraying apparatus is 

classified in heading 8424. 

The subheading does not include apparatus for the assembly of semiconductors 

including die attach apparatus, tape automated bonders and wire bonders. As part 

of the Information Technology Agreement (ITA), new subheadings were created in 

July of 1997 for machinery used in the manufacture of semiconductor devices. The 

1998 HTSUS contained a specific subheading, 8515.80.40, for this ITA equipment, 

at a lower rate of duty than the non-ITA equipment of subheading 8515.80.80. 

When all of subheading 8515.80 became duty free in 1999, this specific ITA 

subheading was dropped. However, the equipment remained classified in 

subheading 8515.80.00 until February 3, 2007. Apparatus of this type, entered on or 

after February 3, 2007, is classified in heading 8486, which provides for machines 

and apparatus of a kind used solely or principally for the manufacture of 

semiconductor boules or wafers, semiconductor devices, electronic integrated 

circuits or flat panel displays; machines and apparatus specified in note 9(C) to 

chapter 84. 

Examples of ITA apparatus previously classified in heading 8515, but migrating to 

heading 8486, as of February 3, 2007, include: 

Die Attach Apparatus - there are two methods, eutectic (classified in 

subheading 8515.80.0080 prior to February 3, 2007) and epoxy (classified in 

subheading 8479.89. 8490 prior to February 3, 2007). 

The eutectic method is named for the phenomenon that takes place when two 

materials melt together at a much lower temperature than either one of them separately. 

The epoxy method uses thick liquid epoxy adhesives; it is not a welding process. 

25
Soldering and Welding Machines and Apparatus 

August 2008 

Note: Non-ITA apparatus using the eutectic method continues to be classified in 

heading 8515, while non-ITA apparatus using the epoxy method continues to be 

classified in heading 8479. 

Wire Bonding - a deformation welding process done with either gold or 

aluminum wires. 

Gold Wire Bonding - there are two methods, thermocompression and 

thermosonic, also known as ball bonding. Thermosonic employs a pulse of ultrasonic 

energy. 

Aluminum Wire Bonding - (no ball is formed) known variously as ultrasonic or 

wedge bonding. 

Tape Automated Bonders - bond is complete with a tool known as a thermode. 

 

Finally, two other processes (non-ITA) of significance under 8515.80 include 

fusion splicers and thermoplastic welders. 

Fusion Splicers - for optical fiber cables, whereby a DC high voltage arc 

generated from electrodes fuses the two optical fibers together. These self-contained 

portable units consist essentially of a fiber guide and clamp, fusion electrodes and 

electrode holders. 

Thermoplastic Welders - the ENs describe machines and apparatus for welding 

thermoplastic materials: 

1. Welding with electrically heated gas (hot gas welding) - the surfaces to be 

joined are warmed by electrically heated gas (generally air) and joined under pressure 

with or without additives. 

2. Welding with electrically heated elements (heated element welding) - the 

surfaces to be joined are warmed by means of electrically heated elements and joined 

under pressure with or without additives. 

3. High-frequency welding - the surfaces to be joined of thermoplastic materials 

(e.g., acrylics, polyethylene, vinyl, nylon) with reasonably high dielectric losses are 

heated in a high frequency alternating field and joined under pressure with or without 

additives. 

Some examples of thermoplastic welders can be found in the following rulings: 

NY 814525, dated September 20, 1995, classified an automatic pocket maker (heat 

welding machine) used to make pockets, primarily out of polypropylene, for papers to be 

inserted in ring binders under subheading 8515.80. 

26
Soldering and Welding Machines and Apparatus 

August 2008 

NY 885988, dated June 1, 1993, classified hot air welding tools under subheading 

8515.80. 

HQ rulings 964783, dated March 27, 2001, and 964638, dated April 12, 2001, classified 

impulse bag sealers for commercial applications under 8515.80. 

Parts 

Subheading 8515.90 - does not include accessories. 

 

Subheading 8515.90.20 - provides for parts of welding machines and apparatus. 

Subheading 8515.90.40 - provides for parts of soldering and brazing machines 

and apparatus and parts of electric machines and apparatus for hot spraying of metal. 

The ENs to heading 8515 provide a few examples of parts: 

soldering heads & tongs 

electrode holders 

metal contact electrodes (contact points, rollers & jaws) 

torch points 

What other items are classified as parts? 

In general, electrical soldering, brazing or welding machine components such as 

beds, bases, columns, frames, rams, etc. will generally be classified as parts if imported 

separately. 

Welding Jigs & Fixtures - in engineering, the terms “jig” and “fixture” have 

essentially the same meaning. The function of a fixture is to facilitate assembly of parts 

and to hold the parts in a fixed relationship. 

Wire Feeders - used to add filler metal during automatic and machine welding. 

The feed may be through the torch or direct to the weld pool. 

Thoriated Tungsten Electrodes (HQ ruling 957718, dated April 5, 1995) – are 

nonconsumable, do not melt, and serve as one of the electrical terminals of the arc. 

Ceramic Welding Nozzle for a TIG welding torch (NY ruling 892522, dated 

December 8, 1993) - as noted earlier, ceramic articles are excluded from heading 8468, 

but not from heading 8515. 

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Soldering and Welding Machines and Apparatus 

August 2008 

 Articles Excluded or Misclassified as Parts 

The heading 8515 ENs exclude: consumable electrodes of base metal or metal 

carbides, classified according to constituent material or in heading 8311; and electrodes 

of graphite or other carbon, with or without metal (heading 8545). 

Although many of the following items have already been mentioned throughout the 

preceding pages, they bear repeating under a discussion of parts because they are 

some of the most frequently misclassified items. The four-digit headings and, where 

possible, the six- or eight- digit subheadings where they are properly classified follow 

the description. 

 Welding transformers - heading 8504 

Welding generators - heading 8502 

Welding control panels - heading 8537 

Welding cables - heading 8544 

Welding helmets - classify according to constituent material 

Lasers - subheading 9013.20 

Nut feeders (HQ ruling 957460, dated April 26, 1995) - heading 8479 

Positioning equipment (HQ 962105, dated April 22, 1999) - heading 8479 - 

headstock-tailstock type and tilting-rotating type. 

Fume extractor (NY ruling 878892, dated October 21, 1992) - 

 subheading 8421.39 - eliminate fumes caused by arc 

 welding. 

Desoldering pump (vacuum pump without any heating element) - 

 subheading 8414.10 

Solder paste - subheading 3810.10 

Solder paste flux - subheading 3810.90 

Solder wire or welding wire - if fluxed, heading 8311 

Solder or welding wire - if not fluxed - classify in the appropriate 

wire provision, e.g., other alloy steel welding wire would be in 

heading 7229 

Measuring instruments related to welding, soldering etc. – various 

 headings in chapter 90 

MACHINES AND APPARATUS OFTEN MISCLASSIFIED UNDER HEADING 8468 OR 

HEADING 8515 

The following are complete machines and apparatus, rather than parts, which 

have been misclassified as soldering, brazing or welding apparatus: 

Wafer Bonders (prior to February 3, 2007, classified in subheading 8479.89.8490; as 

of February 3, 2007, classified in heading 8486) – because silicon is not a thermoplastic 

28
Soldering and Welding Machines and Apparatus 

August 2008 

material. Wafer bonding is achieved through atomic forces, not through a flow of 

material. It is not considered to be a welding process. 

MicroTorches - are multi-purpose, self-contained piezoelectric devices (subheading 

8205.60). 

Thermal cutting machines of the following types: 

Oxyfuel - subheading 8461.90 

Plasma Arc - subheading 8456.90 

Laser Beam - subheading 8456.10 

Veneer Welders - subheading 8465.94 (HQ ruling 089434, dated September 16, 1991) 

- a machine for splicing/joining veneer strips. 

Solder Reflow Ovens - subheading 8514.30 

Solder Leveling Machines - heading 8479 or heading 8424 

Solder Paste Screen Printers - subheading 8443.32.1090 

Bag Sealers - household type, subheading 8516.79 (HQ rulings 962013, 962015 and 

962167, all dated October 1, 1999). These are hand-held devices. 

However, impulse bag sealers of a type for commercial applications are classified 

under subheading 8515.80. (See HQ ruling 964783 of March 27, 2001 and 964638 

of April 12, 2001). They are generally bench top or floor standing units. (It should 

be noted that HQ ruling 964783 revoked HQ ruling 962014 of October 1, 1999 which 

had held that bag sealers of a type used in restaurants and supermarkets were 

classified under heading 8543.) 

Bag sealers incorporating vacuum pumps, conveyors or other mechanical features 

are classified in heading 8422.

 

Hot Air Guns – subheading 8419.89.95. Hand-held devices with a pistol grip which 

incorporate a self-contained electric motor which powers a fan that blows air over a 

ceramic heating element. They are used for various applications including stripping 

paint, soldering copper pipe, removing floor adhesives, window glazing, curing epoxies, 

shrink wrapping plastics, etc. See HQ rulings 960936, dated January 29, 1998, and 

962217, dated April 9, 1999. 

 

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Soldering and Welding Machines and Apparatus 

August 2008 

ADDITIONAL INFORMATION 

The Internet 

The home page of U.S. Customs and Border Protection on the Internet’s World Wide 

Web, provides the trade community with current, relevant information regarding CBP 

operations and items of special interest. The site posts information -- which includes 

proposed regulations, news releases, publications and notices, etc. -- that can be 

searched, read on-line, printed or downloaded to your personal computer. The web site 

was established as a trade-friendly mechanism to assist the importing and exporting 

community. The web site also links to the home pages of many other agencies whose 

importing or exporting regulations that U.S. Customs and Border Protection helps to 

enforce. The web site also contains a wealth of information of interest to a broader 

public than the trade community. For instance, the “Know Before You Go” publication 

and traveler awareness campaign is designed to help educate international travelers. 

 

The web address of U.S. Customs and Border Protection is http://www.cbp.gov

Customs Regulations 

The current edition of Customs and Border Protection Regulations of the United States 

is a loose-leaf, subscription publication available from the Superintendent of 

Documents, U.S. Government Printing Office, Washington, DC 20402; telephone (202) 

512-1800. A bound edition of Title 19, Code of Federal Regulations is also available for 

sale from the same address. All proposed and final regulations are published in the 

Federal Register, which is published daily by the Office of the Federal Register, National 

Archives and Records Administration, and distributed by the Superintendent of 

Documents. Information about on-line access to the Federal Register may be obtained 

by calling (202) 512-1530 between 7 a.m. and 5 p.m. Eastern time. These notices are 

also published in the weekly Customs Bulletin described below. 

Customs Bulletin 

The Customs Bulletin and Decisions (“Customs Bulletin”) is a weekly publication that 

contains decisions, rulings, regulatory proposals, notices and other information of 

interest to the trade community. It also contains decisions issued by the U.S. Court of 

International Trade, as well as customs-related decisions of the U.S. Court of Appeals 

for the Federal Circuit. Each year, the Government Printing Office publishes bound 

volumes of the Customs Bulletin. Subscriptions may be purchased from the 

Superintendent of Documents at the address and phone number listed above. 

30
Soldering and Welding Machines and Apparatus 

August 2008 

Importing into the United States 

This publication provides an overview of the importing process and contains general 

information about import requirements. The current edition of Importing Into the United 

States contains much new and revised material brought about pursuant to the Customs 

Modernization Act (“Mod Act”). The Mod Act has fundamentally altered the relationship 

between importers and U.S. Customs and Border Protection by shifting to the importer 

the legal responsibility for declaring the value, classification, and rate of duty applicable 

to entered merchandise. 

The current edition contains a section entitled "Informed Compliance." A key component 

of informed compliance is the shared responsibility between U.S. Customs and Border 

Protection and the import community, wherein CBP communicates its requirements to 

the importer, and the importer, in turn, uses reasonable care to assure that CBP is 

provided accurate and timely data pertaining to his or her importation. 

Single copies may be obtained from local offices of U.S. Customs and Border 

Protection, or from the Office of Public Affairs, U.S. Customs and Border Protection, 

1300 Pennsylvania Avenue NW, Washington, DC 20229. An on-line version is 

available at the CBP web site. Importing into the United States is also available for 

sale, in single copies or bulk orders, from the Superintendent of Documents by calling 

(202) 512-1800, or by mail from the Superintendent of Documents, Government Printing 

Office, P.O. Box 371954, Pittsburgh, PA 15250-7054. 

Informed Compliance Publications 

U.S. Customs and Border Protection has prepared a number of Informed Compliance 

publications in the “What Every Member of the Trade Community Should Know 

About:...” series. Check the Internet web site http://www.cbp.gov for current 

publications. 

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Soldering and Welding Machines and Apparatus 

August 2008 

Value Publications 

Customs Valuation under the Trade Agreements Act of 1979 is a 96-page book 

containing a detailed narrative description of the customs valuation system, the customs 

valuation title of the Trade Agreements Act (§402 of the Tariff Act of 1930, as amended 

by the Trade Agreements Act of 1979 (19 U.S.C. §1401a)), the Statement of 

Administrative Action which was sent to the U.S. Congress in conjunction with the TAA, 

regulations (19 C.F.R. §§152.000-152.108) implementing the valuation system (a few 

sections of the regulations have been amended subsequent to the publication of the 

book) and questions and answers concerning the valuation system. 

Customs Valuation Encyclopedia (with updates) is comprised of relevant statutory 

provisions, CBP Regulations implementing the statute, portions of the Customs 

Valuation Code, judicial precedent, and administrative rulings involving application of 

valuation law. A copy may be purchased for a nominal charge from the Superintendent 

of Documents, Government Printing Office, P.O. Box 371954, Pittsburgh, PA 15250-

7054. This publication is also available on the Internet web site of U.S. Customs and 

Border Protection. 

The information provided in this publication is for general information 

purposes only. Recognizing that many complicated factors may be 

involved in customs issues, an importer may wish to obtain a ruling under 

CBP Regulations, 19 C.F.R. Part 177, or obtain advice from an expert 

(such as a licensed Customs Broker, attorney or consultant) who 

specializes in customs matters. Reliance solely on the general 

information in this pamphlet may not be considered reasonable care.

Additional information may also be obtained from U.S. Customs and Border Protection 

ports of entry. Please consult your telephone directory for an office near you. The 

listing will be found under U.S. Government, Department of Homeland Security. 

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August 2008 

“Your Comments are Important” 

The Small Business and Regulatory Enforcement Ombudsman and 10 regional 

Fairness Boards were established to receive comments from small businesses about 

Federal agency enforcement activities and rate each agency’s responsiveness to small 

business. If you wish to comment on the enforcement actions of U.S. Customs and 

Border Protection, call 1-888-REG-FAIR (1-888-734-3247). 

REPORT SMUGGLING 1-800-BE-ALERT OR 1-800-NO-DROGA 

Visit our Internet web site: http://www.cbp.gov

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