WEBVTT 00:00:22.767 --> 00:00:24.380 HUANG, PAUL All right. 00:00:24.380 --> 00:00:26.230 Good morning, everyone. 00:00:26.230 --> 00:00:30.300 On behalf of the Office of Trade, the Office of Regulations 00:00:30.300 --> 00:00:33.433 and rulings and the national Commodities Specialist division, 00:00:33.433 --> 00:00:35.433 we welcome you to today's webinar. 00:00:35.433 --> 00:00:41.233 Today's webinar will cover Earth moving machines, specifically those that fall 00:00:41.233 --> 00:00:42.500 in heading 8429. 00:00:42.500 --> 00:00:46.033 My name is Paul Huang and I hope you're providing an introduction 00:00:46.033 --> 00:00:50.733 and overview for the machines of this heading as well as how to classify them. 00:07:51.442 --> 00:07:56.168 HUANG, PAUL In 1925, James Cummings and John Mcloyd applied for 00:07:56.168 --> 00:07:58.633 and were granted a patent for a dirt pushing blade that could attach 00:07:58.633 --> 00:08:00.233 to the front of a tractor. 00:08:00.233 --> 00:08:04.900 HUANG, PAUL Separately invent there's an engineers were also developing 00:08:04.900 --> 00:08:07.689 a steam traction engine, which would eventually lead to an invention 00:08:07.689 --> 00:08:10.720 of a crawler type tractor that used continuous tracks. 00:08:11.766 --> 00:08:13.699 HUANG, PAUL During World War One. 00:08:13.700 --> 00:08:16.833 HUANG, PAUL Crawler tractors were used at the front lines 00:08:16.833 --> 00:08:20.500 where other vehicles cannot handle the money conditions to haul heavy artillery 00:08:20.500 --> 00:08:22.300 and other heavy loads. 00:08:22.300 --> 00:08:25.833 HUANG, PAUL Eventually, the blade and the crawler track 00:08:25.833 --> 00:08:28.833 that would be combined, resulting in a new machine designed 00:08:28.833 --> 00:08:29.900 for plowing fields and clearing land. 00:08:29.900 --> 00:08:35.033 Also during World War One, military bulldozers were used to clear roads 00:08:35.033 --> 00:08:37.233 and to clear supply lines open. 00:08:37.233 --> 00:08:41.233 HUANG, PAUL Over the years, people no longer associate the term bulldozer 00:08:41.233 --> 00:08:42.900 to just the blade. 00:08:42.900 --> 00:08:45.367 Instead, they use the term to refer to an entire machine. 00:08:45.367 --> 00:08:48.100 That is the combined blade and tractor unit. 00:08:52.833 --> 00:08:56.233 HUANG, PAUL Today, bulldozers have become much bigger, more powerful 00:08:56.233 --> 00:08:57.433 and more sophisticated. 00:08:57.433 --> 00:09:01.167 HUANG, PAUL In construction, the blade in the front is used 00:09:01.167 --> 00:09:04.967 to push materials such as soil, sand, snow, rubble or rock, 00:09:04.967 --> 00:09:09.967 while the tracks provide traction and mobility through rough terrain, 00:09:09.967 --> 00:09:12.633 they're also used in both civil 00:09:12.633 --> 00:09:14.367 and military construction projects worldwide. 00:09:17.767 --> 00:09:21.167 HUANG, PAUL What is the difference between a bulldozer and an angle dozer? 00:09:21.167 --> 00:09:24.764 The difference is in the type of bleed used on each machine. 00:09:24.766 --> 00:09:29.966 HUANG, PAUL A bulldozer typically has a blade that is fitted straight 00:09:29.967 --> 00:09:33.095 across the frame and is usually not adjustable but rigid 00:09:33.095 --> 00:09:34.700 so that it can apply a greater amount of force. 00:09:34.700 --> 00:09:39.633 HUANG, PAUL On the other hand, the bleed on an angle dozer can be adjusted 00:09:39.633 --> 00:09:42.967 and positioned at an angle to better push material to one side. 00:09:42.967 --> 00:09:46.367 HUANG, PAUL There are also other types of blades available, 00:09:46.367 --> 00:09:48.300 such as EU shaped blade or pusher block. 00:09:48.300 --> 00:09:49.296 HUANG, PAUL Did you shape? 00:09:49.296 --> 00:09:53.700 Blade has no walls to reduce spillage as material is being pushed and moved. 00:09:53.700 --> 00:09:58.367 HUANG, PAUL A pusher block is more specialized attachment that's used 00:09:58.367 --> 00:10:01.900 to push another machine, such as a scraper or another bulldozer. 00:10:06.233 --> 00:10:08.574 HUANG, PAUL Here we have a photo of a bulldozer. 00:10:16.630 --> 00:10:19.550 HUANG, PAUL As you can see, the blade is relatively flat at the sides 00:10:19.550 --> 00:10:21.700 and is fitted straight across the frame. 00:10:21.700 --> 00:10:24.771 HUANG, PAUL The tractor provides the power and force 00:10:24.771 --> 00:10:27.567 to push the blade forward to clear Earth and other materials. 00:10:27.567 --> 00:10:32.233 HUANG, PAUL So the big take away here is a bulldozer is a machine 00:10:32.233 --> 00:10:36.167 that features a blade at the front of a tractor, and it's principally used 00:10:36.167 --> 00:10:37.633 to push earth and rough leveling. 00:10:41.700 --> 00:10:45.033 HUANG, PAUL Next we move the subheading 8429 twenty, 00:10:45.033 --> 00:10:47.433 which provides for greater than levelers. 00:10:47.433 --> 00:10:51.567 HUANG, PAUL We just looked at bulldozers, which are suited for work 00:10:51.567 --> 00:10:53.833 in construction, land clearing and Rd building. 00:10:54.499 --> 00:10:57.899 HUANG, PAUL Bulldozers are known for their ability to clear land quickly, 00:10:57.900 --> 00:11:00.433 and not necessarily for their precision. 00:11:01.233 --> 00:11:04.300 HUANG, PAUL Instead of a rough clearing performed by a bulldozer, 00:11:04.300 --> 00:11:05.767 a greater is more precise. 00:11:05.767 --> 00:11:10.300 They are able to flatten level mold or grade the material they are working on, 00:11:10.300 --> 00:11:12.900 usually to a given contour or a line. 00:11:12.900 --> 00:11:16.900 Because of this, graders are used in open areas for projects 00:11:16.900 --> 00:11:18.767 that require detail and precision. 00:11:21.833 --> 00:11:24.300 HUANG, PAUL Again, it turned to explanatory notes for guidance. 00:11:24.300 --> 00:11:27.100 HUANG, PAUL It describes greater than levelers as machines designed 00:11:27.100 --> 00:11:31.967 for Earth leveling or smoothing by means of an adjustable grading bleed, 00:11:31.967 --> 00:11:34.500 usually mounted within the wheel base. 00:11:37.167 --> 00:11:41.967 HUANG, PAUL Similar to a bulldozer, a greater uses the blade except the blade 00:11:41.967 --> 00:11:45.167 of a grader is capable of being positioned at multiple angles 00:11:45.167 --> 00:11:47.700 and positions, resulting in greater flexibility. 00:11:48.293 --> 00:11:51.013 HUANG, PAUL But a greater sacrifices power for this flexibility. 00:11:51.013 --> 00:11:55.302 It does not have the center of gravity to provide a large amount of force 00:11:55.302 --> 00:11:57.567 to move Earth like a bulldozer can. 00:11:58.195 --> 00:12:02.832 HUANG, PAUL The earliest graders consisted of a simple steel frame fitted 00:12:02.833 --> 00:12:06.100 with wheels and a fixed angle blade that were pulled by a team of horses, 00:12:06.100 --> 00:12:08.233 oxen or mules. 00:12:08.233 --> 00:12:12.033 HUANG, PAUL Then, in the early 1900s, the horses and mules were replaced 00:12:12.033 --> 00:12:14.500 by steam tractors and crawler tractors. 00:12:14.500 --> 00:12:18.900 HUANG, PAUL It was not until 1919, when the Russell Greater 00:12:18.900 --> 00:12:22.500 Manufacturing Company released a Motor Highway Patrol number one. 00:12:22.500 --> 00:12:25.900 HUANG, PAUL And early self propelled model that featured osteel greater frame 00:12:25.900 --> 00:12:28.100 and blade fitted to a tractor. 00:12:28.100 --> 00:12:31.686 HUANG, PAUL In 1926, Russell introduced tracks 00:12:31.687 --> 00:12:35.767 by using the crawler tractor as the foundation for the Motor Grader. 00:12:35.767 --> 00:12:39.700 HUANG, PAUL Today, the motivator is used in applications beyond forming, 00:12:39.700 --> 00:12:42.567 and it's often used for many kinds of construction operations. 00:12:46.567 --> 00:12:49.700 HUANG, PAUL So Greaters today are self propelled machines that come 00:12:49.700 --> 00:12:51.604 with an adjustable blade which is positioned 00:12:51.605 --> 00:12:53.000 between the front and rear axle. 00:12:53.000 --> 00:12:56.567 HUANG, PAUL And can be used for cutting, spreading and leveling jobs. 00:12:56.567 --> 00:12:59.833 HUANG, PAUL One of the most common applications is to shape 00:12:59.833 --> 00:13:02.567 and grade surfaces during the construction of roads. 00:13:02.567 --> 00:13:05.700 HUANG, PAUL Since these machines are much more versatile than a bulldozer, 00:13:05.700 --> 00:13:10.767 they can also be used to shape shoulders and side slopes along roadways. 00:13:12.033 --> 00:13:14.900 HUANG, PAUL Its versatility comes from the overall unique design. 00:13:14.900 --> 00:13:18.833 As previously mentioned, one of the most unique features 00:13:18.833 --> 00:13:20.500 of a greater is its standard blade. 00:13:20.500 --> 00:13:23.900 HUANG, PAUL The blade is adjustable to many different positions, 00:13:23.900 --> 00:13:24.707 slopes and angles. 00:13:24.707 --> 00:13:27.833 HUANG, PAUL The motor greater may also be articulated 00:13:27.833 --> 00:13:32.033 or hinged to allow horizontal rotation or alignment between the front 00:13:32.033 --> 00:13:33.300 and rear wheels. 00:13:34.033 --> 00:13:37.567 HUANG, PAUL This allows the machine to make tight turns in short radius. 00:13:37.567 --> 00:13:42.233 HUANG, PAUL The front wheels on the modern motor greater can also lean 00:13:42.233 --> 00:13:45.300 at an angle which is useful when the blade needs to be on an incline, 00:13:45.300 --> 00:13:47.767 such as when grading a slope at a large angle. 00:13:47.767 --> 00:13:52.900 HUANG, PAUL Lastly, a grader can be fitted with a variety of attachments, 00:13:52.900 --> 00:13:57.300 including a standard blade, a short blade, a scar fire or Ripper attachment. 00:13:57.300 --> 00:14:01.900 HUANG, PAUL This allows for one machine to break up old pavement 00:14:01.900 --> 00:14:04.033 so that it can be regraded or prepared for a better surface. 00:14:05.033 --> 00:14:06.400 HUANG, PAUL All of these features combined make 00:14:06.400 --> 00:14:08.167 the greater extremely versatile. 00:14:12.367 --> 00:14:15.233 HUANG, PAUL So let's quickly summarize both of the machines 00:14:15.233 --> 00:14:18.367 that we have looked at so far feature of blade or blade attachment 00:14:18.367 --> 00:14:20.633 to perform their principal function of moving Earth. 00:14:20.633 --> 00:14:23.967 HUANG, PAUL A bulldozer features the blade mounted at the front 00:14:23.967 --> 00:14:27.100 of the tractor and is capable of applying a large amount of force. 00:14:27.100 --> 00:14:29.085 HUANG, PAUL A greater features a blade 00:14:29.086 --> 00:14:30.833 in between the front and rear axles, 00:14:30.833 --> 00:14:34.367 which is adjustable, making the machine extremely flexible. 00:14:39.833 --> 00:14:41.567 HUANG, PAUL So far, we've looked at two machines that are used to push 00:14:41.567 --> 00:14:43.233 or clear material. 00:14:43.233 --> 00:14:48.100 But what if a project call for the need to create a larger area 00:14:48.100 --> 00:14:49.767 while also removing the soil? 00:14:49.783 --> 00:14:53.499 Well, next we'll take a look at scrapers under subheading 8429 thirty. 00:14:57.700 --> 00:15:00.100 HUANG, PAUL Originally the scraper was invented 00:15:00.100 --> 00:15:02.300 to increase Earth moving efficiency. 00:15:02.300 --> 00:15:06.033 It was a manually assisted self loading and self dumping machine 00:15:06.033 --> 00:15:08.900 that eliminated the need for shoveling. 00:15:08.900 --> 00:15:12.300 The earlier scrapers were towed and were simple pants pulled by mules 00:15:12.300 --> 00:15:13.700 and horses. 00:15:17.233 --> 00:15:19.326 HUANG, PAUL Today, scrapers are construction equipment 00:15:19.327 --> 00:15:22.733 that scoop up load, haul and dump material. 00:15:22.733 --> 00:15:26.505 HUANG, PAUL They are very effective for operations where loose earth 00:15:26.505 --> 00:15:28.700 must be loaded and moved some distance. 00:15:28.700 --> 00:15:32.300 HUANG, PAUL They include a cutting edge which allows for cutting 00:15:32.300 --> 00:15:34.367 and removing thin layers from the ground surface. 00:15:34.367 --> 00:15:38.100 HUANG, PAUL The cutting edge is located on the front of a hopper or bowl 00:15:38.100 --> 00:15:40.033 that can be raised or lowered when lowered. 00:15:40.033 --> 00:15:43.633 The edge cuts into the soil and fills the hopper. 00:15:43.633 --> 00:15:47.300 HUANG, PAUL The soil can then be hauled away or dumped. 00:15:47.300 --> 00:15:51.433 HUANG, PAUL Alternatively, the scraper can also be used to spread soil 00:15:51.433 --> 00:15:52.967 or material across an area. 00:15:57.145 --> 00:16:01.232 HUANG, PAUL So now that we have an idea of the function of the scraper, 00:16:01.233 --> 00:16:05.367 let's take a look at an example of a scraper that falls in heading 8429 00:16:05.367 --> 00:16:07.233 which are all self propelled. 00:16:07.233 --> 00:16:11.233 HUANG, PAUL The explanatory notes state the heading covers 00:16:11.233 --> 00:16:14.167 only those creepers in which the molar propulsion unit 00:16:14.167 --> 00:16:17.167 and the scraper form an integral mechanical unit. 00:16:17.167 --> 00:16:20.033 HUANG, PAUL For example, trackline scrapers 00:16:20.033 --> 00:16:22.833 in which the scraper body incorporating the cutting edge 00:16:22.833 --> 00:16:24.567 is situated between 2 tracks. 00:16:24.567 --> 00:16:27.833 HUANG, PAUL This heading also includes articulated scrapers, 00:16:27.833 --> 00:16:30.380 which consists of the of a motor propulsion unit 00:16:30.410 --> 00:16:34.569 and a scraper proper equipped with a fixed blade or mobile attachment 00:16:34.570 --> 00:16:35.500 with several blades. 00:16:36.700 --> 00:16:40.850 HUANG, PAUL The photo caption above is an example of an articulated scraper. 00:16:40.850 --> 00:16:43.830 The Motor Propulsion Unit is on the left side of the photo, 00:16:43.830 --> 00:16:47.740 while the scraper with the fixed blade is located on the right side. 00:16:47.740 --> 00:16:51.620 Together both sections with form an integral mechanical unit 00:16:51.620 --> 00:16:54.980 and be considered a self propelled scraper of heading 84 to 29. 00:17:00.433 --> 00:17:04.450 HUANG, PAUL Moving right along, we have subheading 8429 forty, 00:17:04.450 --> 00:17:06.640 which captures tamping machines and road rollers. 00:17:10.767 --> 00:17:13.300 HUANG, PAUL The explanatory notes provide some insight, 00:17:13.300 --> 00:17:18.220 listing Tampin machines as used in rulemaking for packing railroad ballast, 00:17:18.220 --> 00:17:18.540 et cetera. 00:17:18.540 --> 00:17:23.820 HUANG, PAUL The dictionary defines the word tamp as to drive in or down 00:17:23.820 --> 00:17:26.020 by a succession of light or medium blows. 00:17:26.833 --> 00:17:30.160 HUANG, PAUL Or to press a substance down by hitting it several times 00:17:30.160 --> 00:17:30.840 with something heavy. 00:17:34.767 --> 00:17:37.270 HUANG, PAUL To better understand this definition, let's take a look 00:17:37.270 --> 00:17:40.180 at headquarters ruling 966306. 00:17:40.180 --> 00:17:44.770 HUANG, PAUL In this ruling, CVP was presented with two machines. 00:17:44.770 --> 00:17:46.610 HUANG, PAUL A vibratory plate and rammer. 00:17:46.610 --> 00:17:51.040 HUANG, PAUL Both machines were used in road work, construction, 00:17:51.040 --> 00:17:53.290 paving and other earthwork operations. 00:17:54.367 --> 00:17:57.930 HUANG, PAUL The vibratory plates were mainly used for compressing earth, 00:17:57.930 --> 00:18:01.160 clay or gravel to create a level surface. 00:18:01.160 --> 00:18:04.060 HUANG, PAUL A vibratory plate features a heavy plate on the bottom 00:18:04.060 --> 00:18:07.280 of the machine which rapidly moves up and down. 00:18:07.280 --> 00:18:10.320 The combination of rapid impacts, the weight of the plate 00:18:10.320 --> 00:18:13.180 and the impact force compacts the soil underneath the machine. 00:18:14.500 --> 00:18:16.780 HUANG, PAUL In the lower right hand corner we have in photo 00:18:16.780 --> 00:18:19.320 of a vibratory plate compactor. 00:18:19.320 --> 00:18:21.611 These machines are useful in tight spaces 00:18:21.635 --> 00:18:23.653 where a larger roller might not fit. 00:18:24.709 --> 00:18:28.849 We will discuss roller shortly, but essentially they are larger machines. 00:18:28.850 --> 00:18:30.510 There are also used to compact the Earth. 00:18:31.699 --> 00:18:35.569 HUANG, PAUL The ruling also discusses Rammers, which were similar 00:18:35.570 --> 00:18:39.380 to vibratory plates but used the compact, narrower areas 00:18:39.380 --> 00:18:42.460 where it may not be convenient to use a vibratory plate. 00:18:42.460 --> 00:18:45.670 HUANG, PAUL On the left we have a photo of a worker using a Rammer. 00:18:47.191 --> 00:18:49.608 HUANG, PAUL Generally, a rammer consists of a motor, a crankier, 00:18:49.609 --> 00:18:52.160 a spring, and a plate foot. 00:18:52.160 --> 00:18:55.400 HUANG, PAUL The motor generates a torque which is then transferred 00:18:55.400 --> 00:18:57.420 to the crankier as a reciprocating motion. 00:18:58.564 --> 00:19:01.320 HUANG, PAUL The crank your passes this motion to the shore foot 00:19:01.320 --> 00:19:02.320 through the spring. 00:19:02.989 --> 00:19:06.639 As a result, an impact force is passive foot of the tamping rammer. 00:19:09.100 --> 00:19:10.960 HUANG, PAUL Both machines were self propelled 00:19:10.960 --> 00:19:14.530 and controlled behind using handlebars and included a self contained motor. 00:19:15.574 --> 00:19:16.852 HUANG, PAUL In CBP's analysis, 00:19:16.853 --> 00:19:20.160 headquarters discussed two possible headings, 00:19:20.160 --> 00:19:22.320 8467 and 8429. 00:19:24.300 --> 00:19:26.850 HUANG, PAUL Looking for us at heading 8467, 00:19:26.850 --> 00:19:29.860 headquarters emphasized the heading covered tools for working 00:19:29.860 --> 00:19:30.200 in the hand. 00:19:30.200 --> 00:19:34.000 HUANG, PAUL In addition, the tools of the heading were portable 00:19:34.000 --> 00:19:35.960 and can be lifted by a worker. 00:19:35.960 --> 00:19:38.010 In particular, while work is in progress. 00:19:39.299 --> 00:19:42.769 HUANG, PAUL CVP then turned to heading 8429 00:19:42.770 --> 00:19:46.060 and found the heading described the vibratory plates and rammers 00:19:46.060 --> 00:19:47.560 with a greater degree of accuracy. 00:19:48.767 --> 00:19:51.810 HUANG, PAUL First, the machines were designed primarily for Rd building 00:19:51.810 --> 00:19:52.860 and for working on the Earth. 00:19:53.832 --> 00:19:57.929 HUANG, PAUL Second heading 8429 covers a narrower range 00:19:57.930 --> 00:20:01.540 of compacting machines that are explicitly cited in the heading text. 00:20:02.640 --> 00:20:06.010 Taken together, CBB determined that the vibratory plates 00:20:06.010 --> 00:20:10.000 and rammers were classified under subheading 8429 forty. 00:20:15.367 --> 00:20:17.710 HUANG, PAUL Moving right along subheading 8429. 00:20:17.710 --> 00:20:19.980 Forty also provides her self propelled Rd rollers. 00:20:19.980 --> 00:20:24.520 HUANG, PAUL As used in Rd building or other public works. 00:20:24.520 --> 00:20:27.780 HUANG, PAUL These machines are fitted with heavy cast iron 00:20:27.780 --> 00:20:32.650 or steel cylinders of large diameter, smooth or studded with metal feet, 00:20:32.650 --> 00:20:33.610 which press into the soil. 00:20:33.610 --> 00:20:37.770 HUANG, PAUL Or with wheels and heavy solid or pneumatic tires. 00:20:41.100 --> 00:20:43.680 HUANG, PAUL Load rollers are used to compact the Earth. 00:20:43.680 --> 00:20:47.240 Compaction is a mechanical process used to increase the density of soil. 00:20:47.240 --> 00:20:52.910 HUANG, PAUL Road rollers have a long history and without surprise, 00:20:52.910 --> 00:20:55.820 some of the first being pulled again by horses and used 00:20:55.820 --> 00:20:56.850 for agricultural purposes. 00:20:58.167 --> 00:21:00.740 HUANG, PAUL There are many types of Rd rollers. 00:21:00.740 --> 00:21:05.950 Some examples are smooth wheel rollers, grid rollers, sheets with rollers 00:21:05.950 --> 00:21:06.960 and humanic rollers. 00:21:08.567 --> 00:21:10.870 HUANG, PAUL Here we have a photo of a smooth wheeled roller. 00:21:11.967 --> 00:21:13.940 HUANG, PAUL They can either have a single or double drum. 00:21:15.233 --> 00:21:18.590 HUANG, PAUL These types of machines are great for flat surfaces. 00:21:18.590 --> 00:21:23.080 As a result, they are often used for paving, highways and local roads. 00:21:23.080 --> 00:21:26.340 However, they do not have great traction and may not be suited 00:21:26.340 --> 00:21:28.040 for more specialized uses. 00:21:31.300 --> 00:21:33.720 HUANG, PAUL Here we have a single drum or three wheeled roller. 00:21:35.299 --> 00:21:38.709 HUANG, PAUL These machines typically have a steel drum in the front 00:21:38.710 --> 00:21:41.160 and two special wheels in the back. 00:21:41.160 --> 00:21:44.450 These machines are often used when creating foundations for buildings 00:21:44.450 --> 00:21:46.240 or for paving highways or sidewalks. 00:21:49.900 --> 00:21:52.010 HUANG, PAUL Finally, we have sheepsfoot rollers. 00:21:52.633 --> 00:21:56.970 HUANG, PAUL These rollers have special rectangular shaped lugs or feet. 00:21:56.970 --> 00:22:01.050 There are essentially useful when compacting Earth, such as soil 00:22:01.050 --> 00:22:02.540 and clay during road construction. 00:22:03.767 --> 00:22:05.540 HUANG, PAUL One additional thing to note. 00:22:05.540 --> 00:22:08.140 Oftentimes rollers can be either static or vibratory. 00:22:08.140 --> 00:22:11.670 HUANG, PAUL In general, vibratory rollers are able to compact 00:22:11.670 --> 00:22:16.000 with a greater force, increased efficiency and productivity. 00:22:16.000 --> 00:22:19.550 It is also worth noting that the photos and examples provided today 00:22:19.550 --> 00:22:22.010 are our only a small sampling size. 00:22:22.010 --> 00:22:23.980 There are many more designs of rollers available. 00:22:30.389 --> 00:22:33.289 HUANG, PAUL Next, let's take a look at front and shovel loaders 00:22:33.290 --> 00:22:35.040 of subheading 8429. 00:22:35.040 --> 00:22:35.480 Fifty one. 00:22:39.033 --> 00:22:41.190 HUANG, PAUL Item each within the explanatory notes 00:22:41.190 --> 00:22:44.040 describes self propelled shovel loaders. 00:22:44.040 --> 00:22:48.680 It explains these are wheeled or crawler machines with a front mounted bucket 00:22:48.680 --> 00:22:52.330 which picked up material through the motion of the machine transport 00:22:52.330 --> 00:22:52.960 and discharge it. 00:22:52.960 --> 00:22:57.500 HUANG, PAUL Some shovel loaders are able to dig into the soil. 00:22:57.500 --> 00:23:02.100 This is achieved as the bucket when in the horizontal position is capable 00:23:02.100 --> 00:23:04.600 of being lowered below the level of the wheels or tracks. 00:23:06.632 --> 00:23:10.159 HUANG, PAUL A front end loader is a crawler or wheel tractor piece 00:23:10.160 --> 00:23:13.350 of equipment with a bucket container mounted on the front end. 00:23:13.350 --> 00:23:18.880 HUANG, PAUL The bucket is mounted to dig or load material, lift it up, 00:23:18.880 --> 00:23:21.330 carry it, and then dump the material from some height. 00:23:22.767 --> 00:23:24.230 HUANG, PAUL So where is this type of machine useful? 00:23:25.299 --> 00:23:27.999 HUANG, PAUL In general, any construction cleanup operation 00:23:28.000 --> 00:23:32.030 that involves picking up material and dumping it somewhere else is ideal 00:23:32.030 --> 00:23:33.910 for front end loader. 00:23:33.910 --> 00:23:37.230 HUANG, PAUL What I would like to emphasize here is these machines use 00:23:37.230 --> 00:23:39.340 a front mounted bucket. 00:23:39.340 --> 00:23:42.650 We've already looked at bulldozers, graders, and scrapers. 00:23:42.650 --> 00:23:46.990 All of those machines included and utilized a blade or cutting edge 00:23:46.990 --> 00:23:48.140 in this subheading. 00:23:48.140 --> 00:23:50.407 The machines use buckets to pick up material 00:23:50.424 --> 00:23:52.085 using the motion of the machine. 00:23:53.166 --> 00:23:55.869 HUANG, PAUL These machines also differ from excavators, 00:23:55.870 --> 00:23:56.891 which we will look at later on. 00:23:59.300 --> 00:24:02.670 HUANG, PAUL The earliest loaders was designed simply with a rigid frame, 00:24:02.670 --> 00:24:04.650 mechanical arms, and cable controls. 00:24:04.650 --> 00:24:08.800 HUANG, PAUL The cables could only move the bucket straight up and down. 00:24:08.800 --> 00:24:11.650 The digging force and any change in the horizontal position 00:24:11.650 --> 00:24:14.280 of the bucket were dependent on the movement of the tractor. 00:24:16.099 --> 00:24:19.339 HUANG, PAUL Today, a wheel loader may have a rigid base frame, 00:24:19.340 --> 00:24:21.010 or it may have an articulated frame. 00:24:22.049 --> 00:24:26.179 They may be steered by the front axle, rear axle, or all four wheels. 00:24:27.233 --> 00:24:29.440 HUANG, PAUL A wheel loader has an articulated frame. 00:24:30.841 --> 00:24:33.267 HUANG, PAUL That is hinged midway between his two axles. 00:24:34.300 --> 00:24:37.300 HUANG, PAUL This allows the front axle to swing to either side 00:24:37.301 --> 00:24:39.285 of the straightforward position. 00:24:39.286 --> 00:24:41.826 This makes it easier to move and confined spaces. 00:24:46.166 --> 00:24:49.919 HUANG, PAUL So back to the tariff, a wheel loader can have its engine mounted 00:24:49.920 --> 00:24:51.080 in front or in the rear. 00:24:51.080 --> 00:24:54.140 HUANG, PAUL When classifying a wheel loader, 00:24:54.140 --> 00:24:58.350 please be aware the tariff also directs us to classify the loader based 00:24:58.350 --> 00:24:59.360 on the location of the engine. 00:25:00.632 --> 00:25:03.019 HUANG, PAUL Those with a rear engine or classified 00:25:03.020 --> 00:25:09.767 and subheadings 8429 fifty one 1005 to 8429, fifty one 1055. 00:25:11.009 --> 00:25:14.500 HUANG, PAUL If the wheel loader has a front mounted engine, 00:25:14.500 --> 00:25:19.167 the classification would fall the subheading 8429 fifty one 1060. 00:28:52.171 --> 00:28:54.931 HUANG, PAUL The first two types of digging buckets are the shovel 00:28:54.931 --> 00:28:55.933 and backhoe. 00:28:55.933 --> 00:28:59.967 The difference between the shovel and the backhoe is the direction 00:28:59.967 --> 00:29:02.167 of the movement of the bucket as it gets its load. 00:29:02.167 --> 00:29:04.767 HUANG, PAUL On the right, we have a shovel. 00:29:05.122 --> 00:29:07.682 HUANG, PAUL During operation, the shovel moves its bucket up 00:29:07.682 --> 00:29:11.033 and away from the operator. 00:29:11.033 --> 00:29:13.461 HUANG, PAUL On the left we have an example of a backhoe. 00:29:13.461 --> 00:29:16.833 Determine backhoe is often misunderstood. 00:29:16.833 --> 00:29:21.033 It is often mistaken to mean where the mechanical shovel is mounted 00:29:21.033 --> 00:29:22.500 on a self propelled machine. 00:29:22.500 --> 00:29:25.300 HUANG, PAUL Instead, is it is referring 00:29:25.300 --> 00:29:26.967 to the the action of the bucket 00:29:26.967 --> 00:29:30.367 of a backhoe moves its bucket down and towards the operator, 00:29:30.367 --> 00:29:34.767 which helps the dictatorial from below the revolving superstructure. 00:29:38.182 --> 00:29:40.610 HUANG, PAUL Now let's take a look at a clamshell on the left side 00:29:40.610 --> 00:29:41.324 of this slide. 00:29:41.324 --> 00:29:44.967 A clamshell is a bucket with two hinged jaws. 00:29:44.967 --> 00:29:49.233 So imagine two buckets that are hinged in the middle 00:29:49.233 --> 00:29:50.367 to form a call like appendage. 00:29:50.367 --> 00:29:54.433 HUANG, PAUL As it is lowered, the jaw swing open and then close, 00:29:54.433 --> 00:29:55.967 which traps the soil. 00:29:55.967 --> 00:29:58.567 It is then raised and position above the dump site 00:29:58.567 --> 00:30:00.833 where the contents of are empty. 00:30:00.833 --> 00:30:03.900 HUANG, PAUL On the right we have a dragline bucket. 00:30:03.900 --> 00:30:07.833 HUANG, PAUL These buckets are used with machines that use a combination 00:30:07.833 --> 00:30:10.767 of dragging and lifting A to dig and dump material. 00:30:10.767 --> 00:30:15.433 HUANG, PAUL The basic operation involves dragging or pulling the bucket 00:30:15.433 --> 00:30:19.900 along the top layer of material towards the machine using drag cable. 00:30:19.900 --> 00:30:25.167 When the bucket is filled, the operator lifts the bucket using 00:30:25.167 --> 00:30:28.300 a second hoist cable while letting out the drag cable. 00:30:28.300 --> 00:30:31.367 The bucket is then positioned above the dump site 00:30:31.367 --> 00:30:33.056 where the contents are emptied. 00:30:33.087 --> 00:30:37.692 This photo also happens to be a bucket from a very famous dragline excavator. 00:30:41.300 --> 00:30:43.866 HUANG, PAUL So uh quick bit of history. 00:30:43.867 --> 00:30:47.967 The largest drag line ever built was nicknamed the Big Muskie. 00:30:47.967 --> 00:30:52.633 HUANG, PAUL In 1966, the Central Ohio Coal Company 00:30:52.633 --> 00:30:56.967 needed a large enough machine to excavate 110,000 acre property for coal. 00:30:56.967 --> 00:31:01.567 HUANG, PAUL The Bucyrus Erie Company engineered and built the Big Muskie, 00:31:01.567 --> 00:31:04.833 which took 200,000 man hours to complete. 00:31:04.833 --> 00:31:09.033 HUANG, PAUL When construction finish, the excavator was 22 stories tall. 00:31:09.033 --> 00:31:16.767 It weighed £27 million and had a 220 cubic yard bucket capacity, 00:31:16.767 --> 00:31:21.633 which is the equivalent of two greyhound buses and a 310 foot boom. 00:31:21.633 --> 00:31:26.033 HUANG, PAUL Big Muskie served for 22 years until 1991. 00:31:26.033 --> 00:31:29.446 HUANG, PAUL Due to the cost of dismantling, transporting 00:31:29.446 --> 00:31:32.754 and reassembling, it sat unused until 1999, 00:31:32.755 --> 00:31:37.210 before it was eventually dismantled and sold for scrap. 00:31:37.210 --> 00:31:39.330 The only part that survived was the bucket. 00:31:44.167 --> 00:31:47.332 HUANG, PAUL So in summary, the machines classify 00:31:47.333 --> 00:31:48.440 within subheading 8429. 00:31:48.440 --> 00:31:52.121 Fifty two are those machines that include 00:31:52.122 --> 00:31:55.100 a 360 degree soup superstructure. 00:31:55.100 --> 00:31:59.870 The machines which fall under subheading 8429, fifty to 10, are based 00:31:59.870 --> 00:32:04.170 on the digging action of the attachment and include backhoe, shovel, 00:32:04.170 --> 00:32:06.220 clamshell or dragline attachments. 00:32:10.967 --> 00:32:15.260 HUANG, PAUL So that brings us the subheading 8429 fifty nine, 00:32:15.260 --> 00:32:19.759 which covers those machines that are other than front end shovel loaders, 00:32:19.760 --> 00:32:23.220 or machinery with a 360 degree revolving superstructure. 00:32:26.367 --> 00:32:27.810 HUANG, PAUL Let's take a look at an example. 00:32:28.767 --> 00:32:31.620 HUANG, PAUL In this photo, looks like we have a front end shovel loader. 00:32:32.567 --> 00:32:35.080 HUANG, PAUL The machine has a front mounted bucket 00:32:35.080 --> 00:32:37.410 as well as an engine mounted towards the front of the unit, 00:32:38.469 --> 00:32:41.799 but at the same time it also has a backhoe bucket behind the cab. 00:32:41.800 --> 00:32:46.730 HUANG, PAUL So would this machine be classified under subheading 8429? 00:32:46.730 --> 00:32:49.410 Fifty one as a front end shovel loader? 00:32:49.410 --> 00:32:52.830 Or would it be classified under 8429 fifty nine as other? 00:32:55.767 --> 00:32:58.470 HUANG, PAUL Headquarters ruling 955502 00:32:58.470 --> 00:33:03.190 from 1994 Customs reviewed tractor backhoe loaders made 00:33:03.190 --> 00:33:04.120 by Massey Ferguson. 00:33:05.233 --> 00:33:09.250 HUANG, PAUL As the name implies, these were tractor like wheeled vehicles 00:33:09.250 --> 00:33:10.740 with enclosed cabs. 00:33:10.740 --> 00:33:14.130 HUANG, PAUL They were equipped with a front mounted bucket. 00:33:14.130 --> 00:33:22.280 HUANG, PAUL And a rear shovel operating from an articulated boom. 00:33:22.280 --> 00:33:27.280 HUANG, PAUL Headquarters began their analysis 00:33:27.280 --> 00:33:32.280 by reviewing the explanatory notes which stated heading 8429 covered 00:33:32.280 --> 00:33:33.700 self propelled shovel owners. 00:33:36.433 --> 00:33:38.380 HUANG, PAUL We looked at fun and trouble orders. 00:33:38.380 --> 00:33:43.100 We emphasized the fact that they picked up material using a front mounted bucket 00:33:43.100 --> 00:33:44.580 and by using the motion of the machine. 00:33:44.580 --> 00:33:46.942 HUANG, PAUL The Massey Ferguson loaders 00:33:46.943 --> 00:33:48.810 had both of these characteristics 00:33:48.810 --> 00:33:51.750 and therefore fell within the scope of subheading 8429. 00:33:51.750 --> 00:33:52.250 Fifty one. 00:33:52.250 --> 00:33:56.400 HUANG, PAUL But the machine also had a rear shovel operating 00:33:56.400 --> 00:33:57.660 from my articulated boom. 00:33:57.660 --> 00:34:02.240 HUANG, PAUL The real shovel allowed the machine to dig into the soil above 00:34:02.240 --> 00:34:03.420 or below machine level. 00:34:03.420 --> 00:34:07.100 HUANG, PAUL By means of an excavating bucket operated directly 00:34:07.100 --> 00:34:08.560 from the end of a boom or jib. 00:34:08.560 --> 00:34:12.670 HUANG, PAUL The bucket attachment was considered a backhoe 00:34:12.670 --> 00:34:15.720 because allowed the machine to dig by, drawing Earth backwards 00:34:15.720 --> 00:34:16.500 or towards the machine. 00:34:17.767 --> 00:34:19.880 HUANG, PAUL Again to turn backhoe is not referring to 00:34:19.880 --> 00:34:23.380 where the attachment is mounted on the machine, but instead to the action 00:34:23.380 --> 00:34:23.910 of the bucket. 00:34:23.910 --> 00:34:28.220 HUANG, PAUL Therefore, stop hanging 8429 fifty nine 00:34:28.220 --> 00:34:30.060 also merited equal consideration. 00:34:33.700 --> 00:34:37.040 HUANG, PAUL Some determine because these vehicles perform functions 00:34:37.040 --> 00:34:41.410 appropriate to shovel orders and tobaccos, they were composite machines. 00:34:41.410 --> 00:34:44.920 HUANG, PAUL Composite machines are addressed under Note 3 to section 16. 00:34:48.300 --> 00:34:52.330 HUANG, PAUL Let's quickly go over Note 3 to section 16, it reads. 00:34:52.330 --> 00:34:54.540 HUANG, PAUL Unless the context otherwise 00:34:54.540 --> 00:34:59.000 requires composite machines consisting of two or more machines fitted together 00:34:59.000 --> 00:35:02.130 to form a hole and other machines designed for the purpose 00:35:02.130 --> 00:35:06.800 of performing two or more complementary or alternative functions are 00:35:06.800 --> 00:35:10.520 to be classified as if consisting only of that component, 00:35:10.520 --> 00:35:13.460 or as being that machine which performs the principal function. 00:35:13.460 --> 00:35:17.680 HUANG, PAUL With Macy Ferguson's loader, the machine was capable 00:35:17.680 --> 00:35:19.810 of performing 2 alternative functions. 00:35:19.810 --> 00:35:23.160 HUANG, PAUL But principal function cannot be determined. 00:35:23.160 --> 00:35:26.270 You could use the machine as a front end shovel loader 00:35:26.270 --> 00:35:28.690 or you could use the machine as a backhoe shovel. 00:35:29.700 --> 00:35:32.570 HUANG, PAUL Since principal function cannot be determined, 00:35:32.570 --> 00:35:36.190 we again proceed to the explanatory notes for section 16, 00:35:36.190 --> 00:35:40.900 which state where it is not possible to determine the principal function 00:35:40.900 --> 00:35:43.940 and where as provided in node three to the section. 00:35:43.940 --> 00:35:46.550 The context does not otherwise require. 00:35:46.550 --> 00:35:50.170 It is necessary to apply general interpretive rule 3C. 00:35:55.567 --> 00:36:00.280 HUANG, PAUL Applying Rule 3C at the sub heading level between 8429 fifty one 00:36:00.280 --> 00:36:05.770 and 8429 fifty nine, the last in tariff would fall to subheading 8429. 00:36:05.770 --> 00:36:11.050 Fifty nine customs ultimately classified the wheel type backhoe loader 00:36:11.050 --> 00:36:15.310 in subheading 8429 fifty 910 under backhoes, shovels, 00:36:15.311 --> 00:36:17.440 clamshells and drag lines. 00:36:17.448 --> 00:36:20.608 HUANG, PAUL Other than machines with a revolving superstructure, 00:36:21.829 --> 00:36:25.609 just a quick note, these machines are oftentimes referred to simply 00:36:25.610 --> 00:36:29.800 as a backhoe, even though the term backhoe may also be used to refer 00:36:29.800 --> 00:36:30.390 to an attachment. 00:36:32.033 --> 00:36:34.550 HUANG, PAUL So if a company says to you they're looking to import it, 00:36:34.550 --> 00:36:35.600 backhoe. 00:36:35.600 --> 00:36:38.620 It may be a good idea to clarify what is being imported 00:36:38.620 --> 00:36:40.120 so that there is no misunderstanding. 00:36:45.967 --> 00:36:48.580 HUANG, PAUL I also wanted to briefly go over another machine 00:36:48.580 --> 00:36:51.680 that may be used for quote UN quote, special excavation, 00:36:51.680 --> 00:36:55.067 particularly machine used for trenching. 00:38:09.317 --> 00:38:12.184 HUANG, PAUL As we can see, the tears and trenchers 00:38:12.184 --> 00:38:16.433 are very specialized machines whose sole purpose and function is 00:38:16.433 --> 00:38:17.900 to dig a narrow opening in the earth. 00:38:17.900 --> 00:38:21.300 HUANG, PAUL And would be more appropriately classified 00:38:21.300 --> 00:38:23.433 on the subtending 8429 fifty 950. 00:38:28.967 --> 00:38:31.433 HUANG, PAUL Now that we've looked at a variety of machines 00:38:31.433 --> 00:38:35.545 that fall in heading 8429, let's take a look at a machine that will not fall 00:38:35.545 --> 00:38:37.367 in the heading. 00:38:37.367 --> 00:38:41.833 HUANG, PAUL A common machine that you may come across is a skid steer loader. 00:38:41.833 --> 00:38:44.300 HUANG, PAUL What is the skid steer loader? 00:38:44.300 --> 00:38:46.900 HUANG, PAUL It is a small engine power machine with a rigid frame 00:38:46.900 --> 00:38:47.900 and lift arms. 00:38:47.900 --> 00:38:51.567 HUANG, PAUL The machine is capable of using a number 00:38:51.567 --> 00:38:55.033 of attachments including buckets, forks or tools. 00:38:55.033 --> 00:38:59.167 HUANG, PAUL They are able to to maneuver in tight spaces 00:38:59.167 --> 00:39:00.554 and can be wheeled or tracked vehicles. 00:39:00.566 --> 00:39:04.899 One distinguishing characteristic is that the lift arms 00:39:04.900 --> 00:39:06.867 on these machines are located alongside the driver. 00:39:06.867 --> 00:39:08.267 As you can see in this photo. 00:39:09.415 --> 00:39:12.757 HUANG, PAUL So why aren't these machines classified and heading 8429? 00:39:16.767 --> 00:39:20.940 HUANG, PAUL In 1995, the Court of International Tree reviewed vehicles 00:39:20.940 --> 00:39:23.700 known as Thomas Schizophrenia Loaders. 00:39:23.700 --> 00:39:27.290 The machines were described as vehicles that operated at speeds ranging 00:39:27.290 --> 00:39:33.850 from 4.6 to 7.2 mph and could lift 800 to 2300 pounds. 00:39:33.850 --> 00:39:36.470 HUANG, PAUL Each vehicle was also capable 00:39:36.470 --> 00:39:40.590 of using numerous interchangeable attachments, including sweepers, 00:39:40.590 --> 00:39:43.320 pallet forks, angle brooms and buckets. 00:39:43.320 --> 00:39:47.470 HUANG, PAUL As a result, the vehicles were used in many different industries. 00:39:47.470 --> 00:39:50.320 HUANG, PAUL To better understand the opinion issued 00:39:50.320 --> 00:39:53.600 by the court, we must first look at the background of the Thomas gets 00:39:53.607 --> 00:39:54.607 through a loader. 00:39:55.150 --> 00:39:59.740 In 1973, the United States Customs Service issued a classification ruling 00:39:59.740 --> 00:40:02.120 for the Thomas gets to your loader. 00:40:02.120 --> 00:40:06.260 In that ruling, customs classify the vehicles on their item 692. 00:40:06.260 --> 00:40:08.750 Forty of the tariff schedule of the United States. 00:40:09.739 --> 00:40:12.899 The tariff schedule was the predecessor to the Harmonized tariff schedule 00:40:12.900 --> 00:40:13.390 and used today. 00:40:13.390 --> 00:40:17.508 HUANG, PAUL In 1989, when the harmonized tariff schedule 00:40:17.509 --> 00:40:21.930 came into effect, customs classified entries of the Thomas Skid steer loaders 00:40:21.937 --> 00:40:26.967 under subheading 8429 Fifty 110 as front end shovel loaders. 00:40:27.950 --> 00:40:30.340 Tom is equipment challenged his classification, 00:40:30.340 --> 00:40:31.770 which was eventually heard about a court. 00:40:33.271 --> 00:40:35.909 HUANG, PAUL The core compared the language of the tower schedule 00:40:35.910 --> 00:40:38.400 to the language of the harmonized tariff schedule. 00:40:38.400 --> 00:40:41.647 HUANG, PAUL When reviewing heading 8429, 00:40:41.690 --> 00:40:46.820 the court stated the provision does not focus on multipurpose work trucks. 00:40:46.820 --> 00:40:51.430 Instead, it focuses on vehicles which manipulate the Earth or like material. 00:40:51.430 --> 00:40:54.910 HUANG, PAUL After consulting the explanatory notes, 00:40:54.910 --> 00:41:00.500 the court rejected the classification of skid steer loaders and heading 8429, 00:41:00.500 --> 00:41:05.770 emphasizing that heading 8429 covers more specialized kinds of machines, 00:41:05.770 --> 00:41:07.660 such as those which manipulate the Earth. 00:41:07.660 --> 00:41:10.500 HUANG, PAUL Ultimately, the court determined 00:41:10.500 --> 00:41:16.000 that gets the loaders remain classified and heading 8427 based on a finding 00:41:16.000 --> 00:41:19.930 of a uniform and established practice of classifying, Thomas gets 00:41:19.930 --> 00:41:21.760 through a loaders as work trucks. 00:41:23.833 --> 00:41:26.870 HUANG, PAUL The decision written by court is a great point of reference 00:41:26.870 --> 00:41:29.830 and I highly encourage everyone to take a look when you have some time, 00:41:30.829 --> 00:41:34.149 whenever you are trying to classify skits your loader, it is a good idea 00:41:34.150 --> 00:41:36.000 to refer back to this opinion. 00:41:42.367 --> 00:41:45.340 HUANG, PAUL Now I I know I shared a lot of technical information today, 00:41:45.340 --> 00:41:48.830 so I wanted to just quickly summarize the major takeaways from today. 00:41:48.830 --> 00:41:53.850 HUANG, PAUL Heading 8429 covers Earth, digging, excavating 00:41:53.850 --> 00:41:56.387 or compacting machines, and our explicitly cited 00:41:56.388 --> 00:41:58.166 in the heading and which have in common the fact 00:41:58.167 --> 00:41:59.400 that they are all self propelled. 00:42:01.100 --> 00:42:03.490 HUANG, PAUL So what do all these machines have in common? 00:42:03.490 --> 00:42:05.920 Their main purpose is for Earth moving operations. 00:42:05.920 --> 00:42:07.990 HUANG, PAUL There are also self propelled. 00:42:07.990 --> 00:42:11.270 HUANG, PAUL So if you ever find yourself classifying machine 00:42:11.270 --> 00:42:14.570 that is not self repelled, it does not go in heading 8429. 00:42:14.570 --> 00:42:17.500 HUANG, PAUL The first three subheadings 00:42:17.500 --> 00:42:23.280 at the six digit level 8429 eleven, 19 and 20 all feature a blade 00:42:23.280 --> 00:42:24.390 to push and move material. 00:42:24.390 --> 00:42:28.570 HUANG, PAUL This includes bulldozers, angle dozers and graders. 00:42:28.570 --> 00:42:32.129 HUANG, PAUL The next 6 digit subheading, 00:42:32.130 --> 00:42:34.880 8429 thirty, provides a scrapers. 00:42:34.880 --> 00:42:39.490 These machines use a sharp cutting edge that cuts off the top layer of soil 00:42:39.490 --> 00:42:41.110 and passes it to a scraper body. 00:42:42.767 --> 00:42:47.300 HUANG, PAUL Next 8429 forty provides her tamping machines and road rollers. 00:42:48.233 --> 00:42:51.390 HUANG, PAUL These machines are all used to level and compact the ground. 00:42:53.033 --> 00:42:55.490 HUANG, PAUL Front end shovel loaders go in 8429. 00:42:55.490 --> 00:43:00.120 Fifty one these machines feature a bucket attachment in front. 00:43:00.120 --> 00:43:03.490 HUANG, PAUL They used the motion of the machine and a front mounted bucket 00:43:03.490 --> 00:43:06.210 to shovel lift and move material or earth. 00:43:08.367 --> 00:43:12.420 HUANG, PAUL Then we find ourselves in 8429 fifty two, which provides 00:43:12.420 --> 00:43:16.020 for machinery with a 360 degree revolving superstructure. 00:43:17.033 --> 00:43:20.060 HUANG, PAUL Within the subheading, we need to ask ourselves, 00:43:20.060 --> 00:43:22.370 how does this machine move the earth? 00:43:22.370 --> 00:43:26.620 The most common actions being backhoes, shovels, and clamshell attachments. 00:43:27.649 --> 00:43:30.423 HUANG, PAUL Another popular attachment is a drag line 00:43:30.424 --> 00:43:34.010 which uses cables or ropes to control the bucket to move material. 00:43:35.633 --> 00:43:38.360 HUANG, PAUL And finally, we have 8429 fifty nine. 00:43:39.299 --> 00:43:43.759 The other we looked at headquarters ruling 955502 00:43:43.760 --> 00:43:46.890 and looked at a composite machine commonly referred to as a backhoe. 00:43:46.890 --> 00:43:50.620 HUANG, PAUL This machine feature a front mounted bucket 00:43:50.620 --> 00:43:53.420 and a rear mechanical shovel with a backhoe bucket attachment. 00:43:54.767 --> 00:43:58.950 HUANG, PAUL The machine did not have the 360 degree revolving superstructure 00:43:58.950 --> 00:44:01.460 and was classified in subheading 8429. 00:44:01.460 --> 00:44:04.890 Fifty nine by application of GR3C. 00:44:09.900 --> 00:44:13.150 HUANG, PAUL So finally I wanted to share some helpful questions 00:44:13.150 --> 00:44:17.060 that I often ask myself before classifying machine of heading 8429. 00:44:17.060 --> 00:44:20.670 HUANG, PAUL Each question by itself may not necessarily lead 00:44:20.670 --> 00:44:24.330 to a classification, but together they should provide insight 00:44:24.330 --> 00:44:25.800 and narrow down the possibilities. 00:44:28.700 --> 00:44:30.760 HUANG, PAUL So I wanted to finish a little earlier today 00:44:30.760 --> 00:44:33.490 so that we have time for questions. 00:44:33.490 --> 00:44:35.900 So I'll end it right here and we can do that. 00:44:37.500 --> 00:44:38.669 HUANG, PAUL Please note certain questions 00:44:38.670 --> 00:44:42.560 will require additional research and detailed information. 00:44:42.560 --> 00:44:45.010 The best method to provide a detailed analysis 00:44:45.010 --> 00:44:48.720 of your classification concern would be to initiate a binding ruling request. 00:44:48.720 --> 00:44:51.790 HUANG, PAUL But I will try to address a few questions now. 00:44:53.300 --> 00:44:56.470 HUANG, PAUL Please feel free to type your question into the chat box 00:44:56.470 --> 00:44:59.460 and the meantime I will I'll scroll up and see 00:44:59.460 --> 00:45:01.390 if there were any questions from earlier. 00:45:26.367 --> 00:45:27.910 HUANG, PAUL OK, you don't see anything as of yet? 00:45:50.639 --> 00:45:53.300 HUANG, PAUL In regards to the a copy of the presentation, 00:45:53.300 --> 00:45:58.220 I don't think it will be available, but a recording will be posted 00:45:58.220 --> 00:46:04.740 on CBP's website and I think Miriam just posted the link to that that website. 00:46:04.740 --> 00:46:08.750 So just I would say give it maybe a few weeks a little bit 00:46:08.755 --> 00:46:11.659 of time, but eventually it will be posted on there and then you can, 00:46:11.660 --> 00:46:16.284 you know view this the presentation again, I guess at your leisure 00:46:16.309 --> 00:46:19.209 and I guess by extension you can look at the slides at that time. 00:46:36.033 --> 00:46:39.190 HUANG, PAUL OK, there doesn't seem to be any questions, so I guess. 00:46:41.327 --> 00:46:42.830 HUANG, PAUL I guess we'll end it here. 00:46:43.700 --> 00:46:45.180 HUANG, PAUL Ohh actually. 00:46:45.180 --> 00:46:48.180 HUANG, PAUL OK, we do have a question or fixed drive motors 00:46:48.180 --> 00:46:54.670 for many excavators classify under 8430 for general use on their 9817. 00:46:56.100 --> 00:46:59.450 HUANG, PAUL Dad, I think, will probably gonna need 00:46:59.450 --> 00:47:04.290 a little bit more information on, UM, when you say drive motors, 00:47:04.290 --> 00:47:08.460 that sort of sounds more like a part than as a a complete machine. 00:47:08.460 --> 00:47:13.040 HUANG, PAUL So we would probably need a little bit more information 00:47:13.040 --> 00:47:14.490 before we can kind of answer that. 00:47:27.510 --> 00:47:33.159 HUANG, PAUL I don't have anything Umm scheduled yet for 8431, but I think 00:47:33.160 --> 00:47:35.080 in the in the near future we'll we'll definitely look 00:47:35.080 --> 00:47:36.650 into putting something together. 00:47:36.650 --> 00:47:38.040 HUANG, PAUL Umm. 00:47:38.040 --> 00:47:41.330 And then you know, hopefully we can try to address any questions on parts 00:47:41.330 --> 00:47:42.100 on the at that time. 00:47:49.500 --> 00:47:52.000 HUANG, PAUL Sure, I could go back to the scraper slide. 00:48:03.833 --> 00:48:05.780 HUANG, PAUL Not sure if that's the slide you're looking for. 00:48:05.780 --> 00:48:07.400 UM. 00:48:18.100 --> 00:48:18.530 HUANG, PAUL All right. 00:48:18.530 --> 00:48:21.840 Well, I guess if there aren't any more questions, UM, I just want 00:48:21.840 --> 00:48:23.770 to thank everybody for their time today. 00:48:23.770 --> 00:48:26.680 And Umm, you know for attending the the meeting and 00:48:26.680 --> 00:48:29.820 and for your attention and I I hope that this was helpful 00:48:29.820 --> 00:48:34.630 and if anybody has any further questions please feel free to send me an email 00:48:34.630 --> 00:48:36.200 and have a great day. 00:48:36.200 --> 00:48:37.158 So thank you everyone.