HUANG, PAUL All right.
Good morning, everyone.
On behalf of the Office of Trade, the Office of Regulations
and rulings and the national Commodities Specialist division,
we welcome you to today's webinar.
Today's webinar will cover Earth moving machines, specifically those that fall
in heading 8429.
My name is Paul Huang and I hope you're providing an introduction
and overview for the machines of this heading as well as how to classify them.
HUANG, PAUL In 1925, James Cummings and John Mcloyd applied for
and were granted a patent for a dirt pushing blade that could attach
to the front of a tractor.
HUANG, PAUL Separately invent there's an engineers were also developing
a steam traction engine, which would eventually lead to an invention
of a crawler type tractor that used continuous tracks.
HUANG, PAUL During World War One.
HUANG, PAUL Crawler tractors were used at the front lines
where other vehicles cannot handle the money conditions to haul heavy artillery
and other heavy loads.
HUANG, PAUL Eventually, the blade and the crawler track
that would be combined, resulting in a new machine designed
for plowing fields and clearing land.
Also during World War One, military bulldozers were used to clear roads
and to clear supply lines open.
HUANG, PAUL Over the years, people no longer associate the term bulldozer
to just the blade.
Instead, they use the term to refer to an entire machine.
That is the combined blade and tractor unit.
HUANG, PAUL Today, bulldozers have become much bigger, more powerful
and more sophisticated.
HUANG, PAUL In construction, the blade in the front is used
to push materials such as soil, sand, snow, rubble or rock,
while the tracks provide traction and mobility through rough terrain,
they're also used in both civil
and military construction projects worldwide.
HUANG, PAUL What is the difference between a bulldozer and an angle dozer?
The difference is in the type of bleed used on each machine.
HUANG, PAUL A bulldozer typically has a blade that is fitted straight
across the frame and is usually not adjustable but rigid
so that it can apply a greater amount of force.
HUANG, PAUL On the other hand, the bleed on an angle dozer can be adjusted
and positioned at an angle to better push material to one side.
HUANG, PAUL There are also other types of blades available,
such as EU shaped blade or pusher block.
HUANG, PAUL Did you shape?
Blade has no walls to reduce spillage as material is being pushed and moved.
HUANG, PAUL A pusher block is more specialized attachment that's used
to push another machine, such as a scraper or another bulldozer.
HUANG, PAUL Here we have a photo of a bulldozer.
HUANG, PAUL As you can see, the blade is relatively flat at the sides
and is fitted straight across the frame.
HUANG, PAUL The tractor provides the power and force
to push the blade forward to clear Earth and other materials.
HUANG, PAUL So the big take away here is a bulldozer is a machine
that features a blade at the front of a tractor, and it's principally used
to push earth and rough leveling.
HUANG, PAUL Next we move the subheading 8429 twenty,
which provides for greater than levelers.
HUANG, PAUL We just looked at bulldozers, which are suited for work
in construction, land clearing and Rd building.
HUANG, PAUL Bulldozers are known for their ability to clear land quickly,
and not necessarily for their precision.
HUANG, PAUL Instead of a rough clearing performed by a bulldozer,
a greater is more precise.
They are able to flatten level mold or grade the material they are working on,
usually to a given contour or a line.
Because of this, graders are used in open areas for projects
that require detail and precision.
HUANG, PAUL Again, it turned to explanatory notes for guidance.
HUANG, PAUL It describes greater than levelers as machines designed
for Earth leveling or smoothing by means of an adjustable grading bleed,
usually mounted within the wheel base.
HUANG, PAUL Similar to a bulldozer, a greater uses the blade except the blade
of a grader is capable of being positioned at multiple angles
and positions, resulting in greater flexibility.
HUANG, PAUL But a greater sacrifices power for this flexibility.
It does not have the center of gravity to provide a large amount of force
to move Earth like a bulldozer can.
HUANG, PAUL The earliest graders consisted of a simple steel frame fitted
with wheels and a fixed angle blade that were pulled by a team of horses,
oxen or mules.
HUANG, PAUL Then, in the early 1900s, the horses and mules were replaced
by steam tractors and crawler tractors.
HUANG, PAUL It was not until 1919, when the Russell Greater
Manufacturing Company released a Motor Highway Patrol number one.
HUANG, PAUL And early self propelled model that featured osteel greater frame
and blade fitted to a tractor.
HUANG, PAUL In 1926, Russell introduced tracks
by using the crawler tractor as the foundation for the Motor Grader.
HUANG, PAUL Today, the motivator is used in applications beyond forming,
and it's often used for many kinds of construction operations.
HUANG, PAUL So Greaters today are self propelled machines that come
with an adjustable blade which is positioned
between the front and rear axle.
HUANG, PAUL And can be used for cutting, spreading and leveling jobs.
HUANG, PAUL One of the most common applications is to shape
and grade surfaces during the construction of roads.
HUANG, PAUL Since these machines are much more versatile than a bulldozer,
they can also be used to shape shoulders and side slopes along roadways.
HUANG, PAUL Its versatility comes from the overall unique design.
As previously mentioned, one of the most unique features
of a greater is its standard blade.
HUANG, PAUL The blade is adjustable to many different positions,
slopes and angles.
HUANG, PAUL The motor greater may also be articulated
or hinged to allow horizontal rotation or alignment between the front
and rear wheels.
HUANG, PAUL This allows the machine to make tight turns in short radius.
HUANG, PAUL The front wheels on the modern motor greater can also lean
at an angle which is useful when the blade needs to be on an incline,
such as when grading a slope at a large angle.
HUANG, PAUL Lastly, a grader can be fitted with a variety of attachments,
including a standard blade, a short blade, a scar fire or Ripper attachment.
HUANG, PAUL This allows for one machine to break up old pavement
so that it can be regraded or prepared for a better surface.
HUANG, PAUL All of these features combined make
the greater extremely versatile.
HUANG, PAUL So let's quickly summarize both of the machines
that we have looked at so far feature of blade or blade attachment
to perform their principal function of moving Earth.
HUANG, PAUL A bulldozer features the blade mounted at the front
of the tractor and is capable of applying a large amount of force.
HUANG, PAUL A greater features a blade
in between the front and rear axles,
which is adjustable, making the machine extremely flexible.
HUANG, PAUL So far, we've looked at two machines that are used to push
or clear material.
But what if a project call for the need to create a larger area
while also removing the soil?
Well, next we'll take a look at scrapers under subheading 8429 thirty.
HUANG, PAUL Originally the scraper was invented
to increase Earth moving efficiency.
It was a manually assisted self loading and self dumping machine
that eliminated the need for shoveling.
The earlier scrapers were towed and were simple pants pulled by mules
and horses.
HUANG, PAUL Today, scrapers are construction equipment
that scoop up load, haul and dump material.
HUANG, PAUL They are very effective for operations where loose earth
must be loaded and moved some distance.
HUANG, PAUL They include a cutting edge which allows for cutting
and removing thin layers from the ground surface.
HUANG, PAUL The cutting edge is located on the front of a hopper or bowl
that can be raised or lowered when lowered.
The edge cuts into the soil and fills the hopper.
HUANG, PAUL The soil can then be hauled away or dumped.
HUANG, PAUL Alternatively, the scraper can also be used to spread soil
or material across an area.
HUANG, PAUL So now that we have an idea of the function of the scraper,
let's take a look at an example of a scraper that falls in heading 8429
which are all self propelled.
HUANG, PAUL The explanatory notes state the heading covers
only those creepers in which the molar propulsion unit
and the scraper form an integral mechanical unit.
HUANG, PAUL For example, trackline scrapers
in which the scraper body incorporating the cutting edge
is situated between 2 tracks.
HUANG, PAUL This heading also includes articulated scrapers,
which consists of the of a motor propulsion unit
and a scraper proper equipped with a fixed blade or mobile attachment
with several blades.
HUANG, PAUL The photo caption above is an example of an articulated scraper.
The Motor Propulsion Unit is on the left side of the photo,
while the scraper with the fixed blade is located on the right side.
Together both sections with form an integral mechanical unit
and be considered a self propelled scraper of heading 84 to 29.
HUANG, PAUL Moving right along, we have subheading 8429 forty,
which captures tamping machines and road rollers.
HUANG, PAUL The explanatory notes provide some insight,
listing Tampin machines as used in rulemaking for packing railroad ballast,
et cetera.
HUANG, PAUL The dictionary defines the word tamp as to drive in or down
by a succession of light or medium blows.
HUANG, PAUL Or to press a substance down by hitting it several times
with something heavy.
HUANG, PAUL To better understand this definition, let's take a look
at headquarters ruling 966306.
HUANG, PAUL In this ruling, CVP was presented with two machines.
HUANG, PAUL A vibratory plate and rammer.
HUANG, PAUL Both machines were used in road work, construction,
paving and other earthwork operations.
HUANG, PAUL The vibratory plates were mainly used for compressing earth,
clay or gravel to create a level surface.
HUANG, PAUL A vibratory plate features a heavy plate on the bottom
of the machine which rapidly moves up and down.
The combination of rapid impacts, the weight of the plate
and the impact force compacts the soil underneath the machine.
HUANG, PAUL In the lower right hand corner we have in photo
of a vibratory plate compactor.
These machines are useful in tight spaces
where a larger roller might not fit.
We will discuss roller shortly, but essentially they are larger machines.
There are also used to compact the Earth.
HUANG, PAUL The ruling also discusses Rammers, which were similar
to vibratory plates but used the compact, narrower areas
where it may not be convenient to use a vibratory plate.
HUANG, PAUL On the left we have a photo of a worker using a Rammer.
HUANG, PAUL Generally, a rammer consists of a motor, a crankier,
a spring, and a plate foot.
HUANG, PAUL The motor generates a torque which is then transferred
to the crankier as a reciprocating motion.
HUANG, PAUL The crank your passes this motion to the shore foot
through the spring.
As a result, an impact force is passive foot of the tamping rammer.
HUANG, PAUL Both machines were self propelled
and controlled behind using handlebars and included a self contained motor.
HUANG, PAUL In CBP's analysis,
headquarters discussed two possible headings,
8467 and 8429.
HUANG, PAUL Looking for us at heading 8467,
headquarters emphasized the heading covered tools for working
in the hand.
HUANG, PAUL In addition, the tools of the heading were portable
and can be lifted by a worker.
In particular, while work is in progress.
HUANG, PAUL CVP then turned to heading 8429
and found the heading described the vibratory plates and rammers
with a greater degree of accuracy.
HUANG, PAUL First, the machines were designed primarily for Rd building
and for working on the Earth.
HUANG, PAUL Second heading 8429 covers a narrower range
of compacting machines that are explicitly cited in the heading text.
Taken together, CBB determined that the vibratory plates
and rammers were classified under subheading 8429 forty.
HUANG, PAUL Moving right along subheading 8429.
Forty also provides her self propelled Rd rollers.
HUANG, PAUL As used in Rd building or other public works.
HUANG, PAUL These machines are fitted with heavy cast iron
or steel cylinders of large diameter, smooth or studded with metal feet,
which press into the soil.
HUANG, PAUL Or with wheels and heavy solid or pneumatic tires.
HUANG, PAUL Load rollers are used to compact the Earth.
Compaction is a mechanical process used to increase the density of soil.
HUANG, PAUL Road rollers have a long history and without surprise,
some of the first being pulled again by horses and used
for agricultural purposes.
HUANG, PAUL There are many types of Rd rollers.
Some examples are smooth wheel rollers, grid rollers, sheets with rollers
and humanic rollers.
HUANG, PAUL Here we have a photo of a smooth wheeled roller.
HUANG, PAUL They can either have a single or double drum.
HUANG, PAUL These types of machines are great for flat surfaces.
As a result, they are often used for paving, highways and local roads.
However, they do not have great traction and may not be suited
for more specialized uses.
HUANG, PAUL Here we have a single drum or three wheeled roller.
HUANG, PAUL These machines typically have a steel drum in the front
and two special wheels in the back.
These machines are often used when creating foundations for buildings
or for paving highways or sidewalks.
HUANG, PAUL Finally, we have sheepsfoot rollers.
HUANG, PAUL These rollers have special rectangular shaped lugs or feet.
There are essentially useful when compacting Earth, such as soil
and clay during road construction.
HUANG, PAUL One additional thing to note.
Oftentimes rollers can be either static or vibratory.
HUANG, PAUL In general, vibratory rollers are able to compact
with a greater force, increased efficiency and productivity.
It is also worth noting that the photos and examples provided today
are our only a small sampling size.
There are many more designs of rollers available.
HUANG, PAUL Next, let's take a look at front and shovel loaders
of subheading 8429.
Fifty one.
HUANG, PAUL Item each within the explanatory notes
describes self propelled shovel loaders.
It explains these are wheeled or crawler machines with a front mounted bucket
which picked up material through the motion of the machine transport
and discharge it.
HUANG, PAUL Some shovel loaders are able to dig into the soil.
This is achieved as the bucket when in the horizontal position is capable
of being lowered below the level of the wheels or tracks.
HUANG, PAUL A front end loader is a crawler or wheel tractor piece
of equipment with a bucket container mounted on the front end.
HUANG, PAUL The bucket is mounted to dig or load material, lift it up,
carry it, and then dump the material from some height.
HUANG, PAUL So where is this type of machine useful?
HUANG, PAUL In general, any construction cleanup operation
that involves picking up material and dumping it somewhere else is ideal
for front end loader.
HUANG, PAUL What I would like to emphasize here is these machines use
a front mounted bucket.
We've already looked at bulldozers, graders, and scrapers.
All of those machines included and utilized a blade or cutting edge
in this subheading.
The machines use buckets to pick up material
using the motion of the machine.
HUANG, PAUL These machines also differ from excavators,
which we will look at later on.
HUANG, PAUL The earliest loaders was designed simply with a rigid frame,
mechanical arms, and cable controls.
HUANG, PAUL The cables could only move the bucket straight up and down.
The digging force and any change in the horizontal position
of the bucket were dependent on the movement of the tractor.
HUANG, PAUL Today, a wheel loader may have a rigid base frame,
or it may have an articulated frame.
They may be steered by the front axle, rear axle, or all four wheels.
HUANG, PAUL A wheel loader has an articulated frame.
HUANG, PAUL That is hinged midway between his two axles.
HUANG, PAUL This allows the front axle to swing to either side
of the straightforward position.
This makes it easier to move and confined spaces.
HUANG, PAUL So back to the tariff, a wheel loader can have its engine mounted
in front or in the rear.
HUANG, PAUL When classifying a wheel loader,
please be aware the tariff also directs us to classify the loader based
on the location of the engine.
HUANG, PAUL Those with a rear engine or classified
and subheadings 8429 fifty one 1005 to 8429, fifty one 1055.
HUANG, PAUL If the wheel loader has a front mounted engine,
the classification would fall the subheading 8429 fifty one 1060.
HUANG, PAUL The first two types of digging buckets are the shovel
and backhoe.
The difference between the shovel and the backhoe is the direction
of the movement of the bucket as it gets its load.
HUANG, PAUL On the right, we have a shovel.
HUANG, PAUL During operation, the shovel moves its bucket up
and away from the operator.
HUANG, PAUL On the left we have an example of a backhoe.
Determine backhoe is often misunderstood.
It is often mistaken to mean where the mechanical shovel is mounted
on a self propelled machine.
HUANG, PAUL Instead, is it is referring
to the the action of the bucket
of a backhoe moves its bucket down and towards the operator,
which helps the dictatorial from below the revolving superstructure.
HUANG, PAUL Now let's take a look at a clamshell on the left side
of this slide.
A clamshell is a bucket with two hinged jaws.
So imagine two buckets that are hinged in the middle
to form a call like appendage.
HUANG, PAUL As it is lowered, the jaw swing open and then close,
which traps the soil.
It is then raised and position above the dump site
where the contents of are empty.
HUANG, PAUL On the right we have a dragline bucket.
HUANG, PAUL These buckets are used with machines that use a combination
of dragging and lifting A to dig and dump material.
HUANG, PAUL The basic operation involves dragging or pulling the bucket
along the top layer of material towards the machine using drag cable.
When the bucket is filled, the operator lifts the bucket using
a second hoist cable while letting out the drag cable.
The bucket is then positioned above the dump site
where the contents are emptied.
This photo also happens to be a bucket from a very famous dragline excavator.
HUANG, PAUL So uh quick bit of history.
The largest drag line ever built was nicknamed the Big Muskie.
HUANG, PAUL In 1966, the Central Ohio Coal Company
needed a large enough machine to excavate 110,000 acre property for coal.
HUANG, PAUL The Bucyrus Erie Company engineered and built the Big Muskie,
which took 200,000 man hours to complete.
HUANG, PAUL When construction finish, the excavator was 22 stories tall.
It weighed £27 million and had a 220 cubic yard bucket capacity,
which is the equivalent of two greyhound buses and a 310 foot boom.
HUANG, PAUL Big Muskie served for 22 years until 1991.
HUANG, PAUL Due to the cost of dismantling, transporting
and reassembling, it sat unused until 1999,
before it was eventually dismantled and sold for scrap.
The only part that survived was the bucket.
HUANG, PAUL So in summary, the machines classify
within subheading 8429.
Fifty two are those machines that include
a 360 degree soup superstructure.
The machines which fall under subheading 8429, fifty to 10, are based
on the digging action of the attachment and include backhoe, shovel,
clamshell or dragline attachments.
HUANG, PAUL So that brings us the subheading 8429 fifty nine,
which covers those machines that are other than front end shovel loaders,
or machinery with a 360 degree revolving superstructure.
HUANG, PAUL Let's take a look at an example.
HUANG, PAUL In this photo, looks like we have a front end shovel loader.
HUANG, PAUL The machine has a front mounted bucket
as well as an engine mounted towards the front of the unit,
but at the same time it also has a backhoe bucket behind the cab.
HUANG, PAUL So would this machine be classified under subheading 8429?
Fifty one as a front end shovel loader?
Or would it be classified under 8429 fifty nine as other?
HUANG, PAUL Headquarters ruling 955502
from 1994 Customs reviewed tractor backhoe loaders made
by Massey Ferguson.
HUANG, PAUL As the name implies, these were tractor like wheeled vehicles
with enclosed cabs.
HUANG, PAUL They were equipped with a front mounted bucket.
HUANG, PAUL And a rear shovel operating from an articulated boom.
HUANG, PAUL Headquarters began their analysis
by reviewing the explanatory notes which stated heading 8429 covered
self propelled shovel owners.
HUANG, PAUL We looked at fun and trouble orders.
We emphasized the fact that they picked up material using a front mounted bucket
and by using the motion of the machine.
HUANG, PAUL The Massey Ferguson loaders
had both of these characteristics
and therefore fell within the scope of subheading 8429.
Fifty one.
HUANG, PAUL But the machine also had a rear shovel operating
from my articulated boom.
HUANG, PAUL The real shovel allowed the machine to dig into the soil above
or below machine level.
HUANG, PAUL By means of an excavating bucket operated directly
from the end of a boom or jib.
HUANG, PAUL The bucket attachment was considered a backhoe
because allowed the machine to dig by, drawing Earth backwards
or towards the machine.
HUANG, PAUL Again to turn backhoe is not referring to
where the attachment is mounted on the machine, but instead to the action
of the bucket.
HUANG, PAUL Therefore, stop hanging 8429 fifty nine
also merited equal consideration.
HUANG, PAUL Some determine because these vehicles perform functions
appropriate to shovel orders and tobaccos, they were composite machines.
HUANG, PAUL Composite machines are addressed under Note 3 to section 16.
HUANG, PAUL Let's quickly go over Note 3 to section 16, it reads.
HUANG, PAUL Unless the context otherwise
requires composite machines consisting of two or more machines fitted together
to form a hole and other machines designed for the purpose
of performing two or more complementary or alternative functions are
to be classified as if consisting only of that component,
or as being that machine which performs the principal function.
HUANG, PAUL With Macy Ferguson's loader, the machine was capable
of performing 2 alternative functions.
HUANG, PAUL But principal function cannot be determined.
You could use the machine as a front end shovel loader
or you could use the machine as a backhoe shovel.
HUANG, PAUL Since principal function cannot be determined,
we again proceed to the explanatory notes for section 16,
which state where it is not possible to determine the principal function
and where as provided in node three to the section.
The context does not otherwise require.
It is necessary to apply general interpretive rule 3C.
HUANG, PAUL Applying Rule 3C at the sub heading level between 8429 fifty one
and 8429 fifty nine, the last in tariff would fall to subheading 8429.
Fifty nine customs ultimately classified the wheel type backhoe loader
in subheading 8429 fifty 910 under backhoes, shovels,
clamshells and drag lines.
HUANG, PAUL Other than machines with a revolving superstructure,
just a quick note, these machines are oftentimes referred to simply
as a backhoe, even though the term backhoe may also be used to refer
to an attachment.
HUANG, PAUL So if a company says to you they're looking to import it,
backhoe.
It may be a good idea to clarify what is being imported
so that there is no misunderstanding.
HUANG, PAUL I also wanted to briefly go over another machine
that may be used for quote UN quote, special excavation,
particularly machine used for trenching.
HUANG, PAUL As we can see, the tears and trenchers
are very specialized machines whose sole purpose and function is
to dig a narrow opening in the earth.
HUANG, PAUL And would be more appropriately classified
on the subtending 8429 fifty 950.
HUANG, PAUL Now that we've looked at a variety of machines
that fall in heading 8429, let's take a look at a machine that will not fall
in the heading.
HUANG, PAUL A common machine that you may come across is a skid steer loader.
HUANG, PAUL What is the skid steer loader?
HUANG, PAUL It is a small engine power machine with a rigid frame
and lift arms.
HUANG, PAUL The machine is capable of using a number
of attachments including buckets, forks or tools.
HUANG, PAUL They are able to to maneuver in tight spaces
and can be wheeled or tracked vehicles.
One distinguishing characteristic is that the lift arms
on these machines are located alongside the driver.
As you can see in this photo.
HUANG, PAUL So why aren't these machines classified and heading 8429?
HUANG, PAUL In 1995, the Court of International Tree reviewed vehicles
known as Thomas Schizophrenia Loaders.
The machines were described as vehicles that operated at speeds ranging
from 4.6 to 7.2 mph and could lift 800 to 2300 pounds.
HUANG, PAUL Each vehicle was also capable
of using numerous interchangeable attachments, including sweepers,
pallet forks, angle brooms and buckets.
HUANG, PAUL As a result, the vehicles were used in many different industries.
HUANG, PAUL To better understand the opinion issued
by the court, we must first look at the background of the Thomas gets
through a loader.
In 1973, the United States Customs Service issued a classification ruling
for the Thomas gets to your loader.
In that ruling, customs classify the vehicles on their item 692.
Forty of the tariff schedule of the United States.
The tariff schedule was the predecessor to the Harmonized tariff schedule
and used today.
HUANG, PAUL In 1989, when the harmonized tariff schedule
came into effect, customs classified entries of the Thomas Skid steer loaders
under subheading 8429 Fifty 110 as front end shovel loaders.
Tom is equipment challenged his classification,
which was eventually heard about a court.
HUANG, PAUL The core compared the language of the tower schedule
to the language of the harmonized tariff schedule.
HUANG, PAUL When reviewing heading 8429,
the court stated the provision does not focus on multipurpose work trucks.
Instead, it focuses on vehicles which manipulate the Earth or like material.
HUANG, PAUL After consulting the explanatory notes,
the court rejected the classification of skid steer loaders and heading 8429,
emphasizing that heading 8429 covers more specialized kinds of machines,
such as those which manipulate the Earth.
HUANG, PAUL Ultimately, the court determined
that gets the loaders remain classified and heading 8427 based on a finding
of a uniform and established practice of classifying, Thomas gets
through a loaders as work trucks.
HUANG, PAUL The decision written by court is a great point of reference
and I highly encourage everyone to take a look when you have some time,
whenever you are trying to classify skits your loader, it is a good idea
to refer back to this opinion.
HUANG, PAUL Now I I know I shared a lot of technical information today,
so I wanted to just quickly summarize the major takeaways from today.
HUANG, PAUL Heading 8429 covers Earth, digging, excavating
or compacting machines, and our explicitly cited
in the heading and which have in common the fact
that they are all self propelled.
HUANG, PAUL So what do all these machines have in common?
Their main purpose is for Earth moving operations.
HUANG, PAUL There are also self propelled.
HUANG, PAUL So if you ever find yourself classifying machine
that is not self repelled, it does not go in heading 8429.
HUANG, PAUL The first three subheadings
at the six digit level 8429 eleven, 19 and 20 all feature a blade
to push and move material.
HUANG, PAUL This includes bulldozers, angle dozers and graders.
HUANG, PAUL The next 6 digit subheading,
8429 thirty, provides a scrapers.
These machines use a sharp cutting edge that cuts off the top layer of soil
and passes it to a scraper body.
HUANG, PAUL Next 8429 forty provides her tamping machines and road rollers.
HUANG, PAUL These machines are all used to level and compact the ground.
HUANG, PAUL Front end shovel loaders go in 8429.
Fifty one these machines feature a bucket attachment in front.
HUANG, PAUL They used the motion of the machine and a front mounted bucket
to shovel lift and move material or earth.
HUANG, PAUL Then we find ourselves in 8429 fifty two, which provides
for machinery with a 360 degree revolving superstructure.
HUANG, PAUL Within the subheading, we need to ask ourselves,
how does this machine move the earth?
The most common actions being backhoes, shovels, and clamshell attachments.
HUANG, PAUL Another popular attachment is a drag line
which uses cables or ropes to control the bucket to move material.
HUANG, PAUL And finally, we have 8429 fifty nine.
The other we looked at headquarters ruling 955502
and looked at a composite machine commonly referred to as a backhoe.
HUANG, PAUL This machine feature a front mounted bucket
and a rear mechanical shovel with a backhoe bucket attachment.
HUANG, PAUL The machine did not have the 360 degree revolving superstructure
and was classified in subheading 8429.
Fifty nine by application of GR3C.
HUANG, PAUL So finally I wanted to share some helpful questions
that I often ask myself before classifying machine of heading 8429.
HUANG, PAUL Each question by itself may not necessarily lead
to a classification, but together they should provide insight
and narrow down the possibilities.
HUANG, PAUL So I wanted to finish a little earlier today
so that we have time for questions.
So I'll end it right here and we can do that.
HUANG, PAUL Please note certain questions
will require additional research and detailed information.
The best method to provide a detailed analysis
of your classification concern would be to initiate a binding ruling request.
HUANG, PAUL But I will try to address a few questions now.
HUANG, PAUL Please feel free to type your question into the chat box
and the meantime I will I'll scroll up and see
if there were any questions from earlier.
HUANG, PAUL OK, you don't see anything as of yet?
HUANG, PAUL In regards to the a copy of the presentation,
I don't think it will be available, but a recording will be posted
on CBP's website and I think Miriam just posted the link to that that website.
So just I would say give it maybe a few weeks a little bit
of time, but eventually it will be posted on there and then you can,
you know view this the presentation again, I guess at your leisure
and I guess by extension you can look at the slides at that time.
HUANG, PAUL OK, there doesn't seem to be any questions, so I guess.
HUANG, PAUL I guess we'll end it here.
HUANG, PAUL Ohh actually.
HUANG, PAUL OK, we do have a question or fixed drive motors
for many excavators classify under 8430 for general use on their 9817.
HUANG, PAUL Dad, I think, will probably gonna need
a little bit more information on, UM, when you say drive motors,
that sort of sounds more like a part than as a a complete machine.
HUANG, PAUL So we would probably need a little bit more information
before we can kind of answer that.
HUANG, PAUL I don't have anything Umm scheduled yet for 8431, but I think
in the in the near future we'll we'll definitely look
into putting something together.
HUANG, PAUL Umm.
And then you know, hopefully we can try to address any questions on parts
on the at that time.
HUANG, PAUL Sure, I could go back to the scraper slide.
HUANG, PAUL Not sure if that's the slide you're looking for.
UM.
HUANG, PAUL All right.
Well, I guess if there aren't any more questions, UM, I just want
to thank everybody for their time today.
And Umm, you know for attending the the meeting and
and for your attention and I I hope that this was helpful
and if anybody has any further questions please feel free to send me an email
and have a great day.
So thank you everyone.