>> Good afternoon, my name is Lynn and
thank you for joining us for the
machines of heading 8427 Webinar.
Today's Webinar is part of the 2023
educations commodity specific Webinar
series and has an expected duration of
about one hour. We have a few
housekeeping rules. Everyone will be
kept on mute during the presentation so
we can keep the line clear of any
background noise. If you have any
questions or comments, we invite you to
type those into the chat box at any time
during the presentation. We will try to
answer as many questions as we can from
the chat box at the end of the
presentation. And the continuing
education credit code for today's
Webinar will be placed in the chat box
throughout the presentation.
Today's presenter is Mr. Wang, over to
you.
>> Mr. Wang: Thank you, Lynn! Good
afternoon everyone. I hope everyone is
having a great day and more importantly,
a better summer. On behalf of the
office of trade, the office of
regulations and rulings and the national
commodities specialist edition, we
welcome you to today's Webinar. This is
machines of heading 8427. My name is
Paul Wong and I'm be introducing an
introduction and overview of the
heading. Today's session will last
approximately one hour with the
presentation taking roughly 45 minutes
of that time. To ensure that we able to
cover all of the information, I do ask
for your patience. There will be a
session towards the end of the
presentation to answer or clarify any
questions on the material. I would also
ask that you hold any questions that
come up during the presentation until
the end but as always, if you think of
any questions as we're moving along,
feel free to type them in the chat box.
Before we get started, we have a few
administrative slides to cover.
We'll start with the mission
statement. Our mission is to protect
the American people, safeguard our
borders and enhance the nation's
economic prosperity. A mission of the
office of trade is to facilitate
legitimate trade and enforce U.S. laws
and protect the American economy to
ensure consumer safety and to create a
level playing field for American
businesses.
Please note the disclaimer. This
Webinar is for general information
purposes only and is intended as
guidance. Also, note the line solely on
the general information on this Webinar
is not considered reasonable care.
Recognizing many complicated factors may
be involved in customs issues and
importer may wish to obtain guidance
from private sector experts who
specialize on custom's matters such as a
licensed broker, or attorney. This is
provided solely to provide context for
the content provided. The audio-visual
media is for educational purposes only
and does not represent an endorsement or
approval of any creators or products.
Here we have some information about
CBP's ruling program. Without a doubt,
you will find we do not cover every
aspect of each machine. These machines
are complicated and can have different
features brand to brand or model to
model. This is to help with a framework
of this heading and to provide the
examples of the machines that fall in
the sub headings. If you have a
specific machine and are unsure of the
classification, we encourage the trade
to submit a request for a binding rules.
CBP's website allows the request to be
filed electronically and the link to
that web page is found on the slide.
This slide includes my contact
information. I'm looking in New York at
the world trade center in lower
Manhattan and part of the office of
NIS103 with the national modties
specialist edition and there's chapters
84, 85 and chapter 93. I will also
share my contact information again
towards the end of the presentation. So
don't worry if you didn't get a chance
to write it down at this time. So as
previously mentioned, today's topic will
cover heading 8427. Many of you are
familiar with these machines. I ask
that you please bear with me. Today's
presentation is for those who are
unfamiliar or even those who need a
refresher. We'll go over the text of
the heading and review the explanatory
notes and go through each of the sub
headings and look at examples of
different machines and lastly, we'll
discuss some helpful tips and things to
consider when classifying merchandise of
8427. So on this screen, we have a
screen shot. It covers forklift trucks,
other trucks fitted with lifting or
handling equipment. We'll start with
the explanatory notes. Also referred to
as the EN. As we may have heard and
head in rulings, this description and
coding system provided a commentary on
the scope of each heading of the
harmonized schedule and are generally
indicative of the general interpretation
of such headings. The EN, the heading
8427 start off by saying, with the
exception of straddle carriers and work
trucks fitted with a heading covers work
trucks with fitted and lifting handling
equipment. This covers KRAENs, mobile
lifting frames, straddle carriers and
work trucks fitted with the crane. The
very last part of this, overlaps with heading
4827 as they both mention the term work
trucks. As such, it's important that we
take time to go over the meaning of this term.
Nor is it defined in the legal text of the
harmonized schedule.
This is specifically and headquarters
ruling, 9456477 in 1994, this is a
personal platform on a wooden base. The
analysis described the term work trucks
stating that heading 8427 in part covers
work trucks both self-propelled and
those not, fitted with lifting or
handling equipment. The term truck is
not defined in the legal text of the
HSTSS or the EN. Keeping this in mind,
let's go through the explanatory notes.
The explanatory notes are basically
separated in two sections. Part A
covers forklift and other elevating or
stacking trucks, paragraph 1 covers
mechanically propelled forklift trucks
that carry a load on an elevated
carriage sliding on a vertical mass.
The lifting mechanism is normally
situated in front of the driver's seat
and designed to support the mode during
movement and lifted for stacking and be
to place on a vehicle. This group
basically includes side loading,
stacking trucks that are designed to
handle loads and usually equipped with a
platform to transport over short
distances. So this is basically
describing the machines that operate in
a specific manner.
Specifically mentioning an elevated
carriage, slideings on a vertical mass.
Paragraph two covers other stacking
machines that are usually mounted on a
truck and are equipped with a platform
or fork which can be raised and lowered
in vertical support by hand or power
operated wench or rack system. I won't
spend too much time on this right now
but we're going to come back to this
later on.
Part B of the explanatory notes
outline other work trucks. This group
includes trucks with mechanically
elevating platforms for the maintenance
of electric cables, public lighting
systems and et cetera. This describes
machines such as Ariel lift patterns,
sometimes referred to as mobile
elevating platforms. Item two cover LS
other trucks fitted with lifting or
handling equipment including those
specialized for use in particular
industries. These will be trucks with
specialized lifting equipment, specific
to a task or industry, such as the
textile, ceramic industries. Now we
have an idea of the types of work trucks
that fall in this heading, we'll go
through the sub headings. First two
indentations at the 6 digit level are
8427.10 and 8427.20. They cover
self-propelled trucks with 8427.10
covered by those with electric motor and
the other covering the others. Some
examples are the others, trucks powered
by hydrogen, gasoline, et cetera. Since
the sub headings marry each other
closely, for the purposes of today's
method, we're going to talk about how
they operate instead of powered.
The big take away is for
classification purposes, you must
determine how each machine is powered
before moving on to the 8th digit sub
heading. The first sub heading we come
across is writer type counter balance
fork trucks. Some of you may be
familiar with these machines and seen
them during the course of the daily
lives. If you have ever worked in a
warehouse, driven past the loading area
of a big box store or supermarket, you
may have seen it around.
To get a better understanding, let's
break it down to sections so the first
part of the type says, work trucks must
be rider type. This refers to a seat,
sometimes within the cab where the
operator controls the machine. Writer
type can mean a type with a platform
standing like the seater type, the
platform is within reach of the controls
to operate the trucks.
The second part says the trucks are
counter balanced meaning, using a
counter weight, opposite of the lifting
mechanism. In this photo, the lifting
mechanism is located in the front two
wheels and the counter weight is
positioned towards the rear of the truck
and the very last part says the lifting
mechanism using forks or steal fingers
inserted under a load like a pallet or
bin, hence the name, forklift truck.
Here we have illustrative
representations of rider types. One on
the left is the model design for a
worker to operate in a seated position.
The major components of a forklift
include a mast, operator cab, over head
guard and forks. The mast is the
vertical support that allows it to
raise, lower and put in position. In
addition to raising and lowering the
load, it can tilt so the forks can be
adjusted relative to the ground. The
forks are usually used to make direct
contact with the load for transport.
The operator cab can be opened or
enclosed. And there's a space where the
controls are located and also where
forklift operators sits. You may also
find many forklifts include an
overhead's guard whose purpose is to
protect the operator from falling object
and consents. On the right, we have an
illustration of a forklift that is
operated in a standing position. In
both pictures, it's located in the front
of the front axel and just to note,
there's many variations and rider type
fork trucks, one example that comes to
mind is the swing mass forklift for
those who are familiar. It's basically,
those kind of trucks that allow the
mast, you know, usually fitted with
forks to swing or turn to the side which
allows the side loading or other
maneuvers that are suitable for narrow
isle operations.
The next sub heading is 8427.10.80,
this is described in the statistical
note 3 of the chapter. If you go to the
note, you'll see it states for the
purposes of statistical reporting
numbers, 8427.10, 8020, 0840, 8070,
8020, this incorporates a platform
attached to a lift mechanism, mounted on
a mobile base for lifting personnel
tools and materials.
So let's look at some examples. So
here we have a photo of the SDIZer lift
that fits the criteria. From the top
down, you have a platform that is used
for that. Next, we have the SDIZ SDER
arm -- and a mobile base that can
transport the entire machine from
location to location.
In this photo, we have an example of a
telescoping boom lift and one that is
lifting personnel, materials and in the
middle, a lift mechanism which in this
case is a telescoping boom assembly and
lastly, we have a mobile base as used to
support the entire boom lift.
And here is our last example of an
Arial work platform. We have a photo of
a variation of a boom lift, specifically
articulated boom lift. This differs
from the telescoping boom lift, the arms
are JOINLTed and consistent of segments
making it a better choice if they need
to maneuver around the obstacle, for
example. But the telescoping lift has
all of the features of the aerial flat
form that goes into 8427. First, it has
a platform used to lift materials or
workers and it also has a mechanism that
is extending from the mobile base. And
lastly, we have a mobile base that is
used to transimportant the entire boom
lift.
The next sub heading we come across is
8427.10.80. This provides for other
operator riding trucks. The trucks
describe under item A2 of the
explanatory notes we looked at either
that fall in this sub heading. So let's
go back to that note. Basically
paragraph two says other stacks machines
usually mounted on a truck and are
equipped with a platform or fork which
can be raised and lowered with vertical
support by hand or power operated wench
or rack system used for stacking sacks,
crates, casks, et cetera. So this is
particular type of lifting truck so
let's look at an example. Straddle
trucks or lifts are a common truck used
to load or unload pallets. Their
distinguished characteristic is the load
capacity and stability are determined by
the out rigger arms, hence the name
straddle lift. Because of the design,
it must be contained between the two
straddles. Just a note of caution,
straddle lifts like many of the trucks
in this heading are made in multiple
configurations. Some may be designed
for an operator to ride on and some are
not. The photos in the slide are meant
to depict types of straddle lifts that
are operator riding.
Other examples of operator running
trucks include reach trucks and order
pickers. So to the right we have an
example of a machine advertised as an
order picker. But an order picker is
unique, it's able to lift the operator
to a certain height which allows the
operator to pick or retrieve items from
a pallet, shelf or rack. In other
words, they can pick it as they drive up
and down the isle.
A reached truck is a variation of the
straddle truck in that, it also has a
mechanism that is capable of extending
the loads that can be carried away from
the machine. This will be useful in
situations, like, for example, where one
may need to place a load towards the
rear of a rack such as an double deep
palette racking system. So next we come
to 8427.10.40 and 50. These are
vehicles fitted with lifting or handling
equipment. So provide a little bit of
background, some of the earliest guided
vehicles were industry manufacturing
handling vehicles that use wires to
guide them along the warehouse or
factory. Automated guided vehicles or
AGV travel along a route demarcated by
sensors, light beams or induction tape.
Since they're predictable and their
speed is relatively low, some argue that
they are safer to operate and also,
because they lack an operator, it
eliminated human errors and makes them
much more efficient.
One of the better definitions that I
can find describe an automated guided
vehicle as a programmable, mobile
vehicle used in industrial applications
to move materials around the
manufacturing facility. They are fully
automated and have the ability to make
decisions such as past selection. The
method in which each vehicle makes
decisions can vary. With some methods
being landmarked based navigation or
vision based navigation. An automated
guided vehicle is a broad term that
covers a number of different machines.
So I think the big take away here is
that those that have fallen in heading
8427 are specifically for vehicles
fitted with lifted and handling
equipment.
Let's take a look at a ruling issued
in 1992 for such a vehicle. In the New
York ruling, they reviewed an automated
guided vehicle that was a machine that
one, consisted of a steal frame. Two,
incorporated a lift table to pick up and
drop off palettes and use electric
motors for travel. It was fitted with
an antenna allowed on a wire. The
vehicle was equipped with another
antenna and control unit so it could
send information regarding position, to
a central control station and receive
instructions on where to travel to
reload. CBP classified this sub
heading, which at the time provided for
other work trucks fitted with lifting or
handling equipment. Self-propelled and
automated guided vehicle.
It was powered by an electric motor
and automated in that the vehicle
followed the wire embedded in the floor
and that would require a worker to
operate. So here we have a photo of a
straddle lift that operates as an
automated guided vehicle. This
particular machine has all of the
characteristics of a straddle lift. It
has out rigger arms, the lifting
mechanism between arms and is used to
lift, load and retrieve palettes but it
differs in that it lacks a platform for
the operator to sit and stand on. It's
designed to be completely automated and
does not require human intervention.
The next two sub headings on the
842710.80 provide for self-propelled,
powered by other, other. This covers
the other, or said differently, trucks
that are neither operator riding or
automated guided vehicles.
Upon the piece of machinery that falls
in this heading is powered jacks.
Depending on how you are introduced in
these machines, they can be referred to
as walking trucks, palette jacks and
pumps and I'm sure, many other names.
So on the left here, we have a photo of
the battery powered electric power jack.
This unit is self-propelled but notice,
it does not have a platform for the
rider to stand on. Also, it is not
considered an automated guided vehicle
as it requires them to maneuver and
operate the machine. An accurate
description must be a walk behind
powered jack. This shows a machine that
features palette wheels, two located
under the forks used to move it back and
forwards. There's also a third wheel
located under the handle which is used
to push, pull, or steer the truck. And
similarly on the right, we have a photo
of a Waccing stacker on the back of a
lift gate. This is similar to the
palette jack as it is also
self-propelled and there's no stand for
the operator to ride on during
operation.
Going on with this, there's some other
types of machines worth mentioning.
Straddle lifts or straddle stackers fall
within the sub heading. They are not to
be confused with the straddle lifts we
looked at earlier, they operate to ride
on the truck. The TRKs that fall under
this, and 8059 are models and
configurations which are designed for
the operator to stand beside while
operating. These are not to be confused
with straddle carriers used at ports of
industry to remove containers.
Straddle lifts are commonly used in
warehouses to move and store palettes
and use indeed areas where the isles are
narrow. They have forklift that are
used to lift and raise them. Straddle
lifts differ from the palette truck we
just looked at, if they have the ability
to raise it to a greater height. Just
keep in mind with all of these sub
headings, there's other designs and
types of trucks that fall under, fall
within the sub heading but, in the
interest of time, we won't be able to
cover all of them.
Since we're on the subject of straddle
lifts, I just want to spend a little bit
of time on the term that can be mistaken
for which is a straddle carrier, they
are referred to as straddle trucks so it
can be confusing.
But they are a type of machine used to
lift ocean containers by straddling them
under the frame. So they are found in
port operations. This includes language
that states with the exception of
straddle carriers and work trucks fitted
with this, this heading covers work
trucks fitted with lifting or handling
equipment. Here is a photo of a
straddle carrier moving the container.
You can kind of see from the size and
method of the operation, that these are
really large pieces of machinery and
they differ from the machines of heading
8427. In headquarters ruling, you can
see it provides an example of the
machine.
This looks at a straddle container,
self-propelled to load, unload, stack
and transport containers over short
distances. It consisted of a large
steel superstructure,/chassis mounted on
two parallel sets of wheels. This also
included a superstructure opened at both
ends that permit the straddle carrier to
remove it and straddle the container to
be lifted.
Lastly, it's on the top for clear
visibility. There's kind of a lot of
extrapolating from this ruling but it's
helpful as it does a good job. Because
it meets the terms of the heading, this
is not classified this way. If you
compare this description that we looked
at earlier, they are kind of very
different in the way they operate. They
are used in different environments.
Different applications. And they just
generally look different from one
another.
So following this heading, we come to
8427.20, other than those propelled by a
motor. We can see from the sub heading
text from the 6 digit level, it mirrors
those electrically powered. It has a
rider type, counter balanced forklift
trucks, and these tend to operate in the
same manner as an electrically powered
model but use a different energy source
and again, some other types of fuel
sources are liquid, gas and et cetera.
This is further broken down to aerial
work flat forms and others. With this,
an example is a machine used to use
combustion engine instead of a motor.
These require more power. What is note
to be missing is the sub heading of
automated guided vehicles with the
provision for other. I'm not saying
there aren't any that don't use
electricity as a fuel source, and I'm
sure someone in the audience would be
able find an example of one, but just
note for classification purposes, they
are classified under the other.
Once again, this is similar to the
end, as the counter parts electrically
powered. The non electric versions,
however, are commonly designed to can
use outdoors and challenging conditions.
So again, because many of the types of
work trucks look the same as the
electric counter parts, I wasn't able to
find a great deal of examples, however,
I could find one that has a liquid gas
cylinder strapped to the rear of the
vehicle. Although not definitive, if
you're ever sure of this, the presence
of a fuel cylinder or tank could be a
give away that it needs to be looked at
for 8427.90. So we have reached the
last six digit break out. This covers
other trucks. This sub heading is the
residual heading within 8427 and covers
those trucks that are not
self-propelled. It covers a number of
different and unique machines, not
covered under 8427 or 8427.20. We will
take a look at a few examples. Here we
have a photo of a manual palette jack.
This is different than what we looked at
earlier. In that the manual pallet jack
is not self-propelled but requires you
to push or pull. The lifting mechanism
in this example is also manually
operated. So the tiller functions at
the pump handle and asks upon the
hydraulic fluid causing it to lift or
unload.
Here we have a different example of a
manual straddle lift truck. This
machine is not very complex being it
lacks an electric motor, but it does
have a handle and pump that would be
used to lift the forks and the object
that is placed upon it. So let's look
at this a little bit more complex and
turn it back to the headquarters ruling
956477. This ruling concerns a personal
platform described as closed, enclosed
personal platform attached to an
articulated hydraulic lifting arm. And
also included is a battery operated arm
that can be used using controls to
maximum working height of 21 feet. The
personal platform is suitable for aerial
work, either inside or outside. It was
not self-propelled and must be towed by
a car between job sites.
First, they stated that this heading
covers work trucks, both self-propelled
and those not self-propelled. Fitted
with lifting or handling equipment.
Secondly, they stated that the term
truck is not defined in the legal text
of the HCS nor in the EN. However, it's
common meeting was broad enough to
encompass wheeled frames for moving
heavy objects and third, the EN
described trucks with mechanically
elevating platforms for the maintenance
of electric cables, public lighting
systems and et cetera. So taking
everything together, the personal
platform at the terms of heading 8427 as
a work truck, it was fitted with lifting
equipment and it was classified under
8427.90.
Here we have another ruling, New York
E84483. This ruling looked at the DINO
lift. This consists of a two wheel
trailer chassis, four out riggers,
articulated arm with a cage. It
contained a hitch that allows it to be
towed from job site to job site. This
is a sub heading 8427.90. The reason
being it was fitted with lifting
equipment, at the same time, still need
today be towed from job site to job
site. I wasn't able to find a photo of
the DINO lift but here's a picture of
what I imagine is similar to the lift
described in the headquarters in New
York ruling. It has a hitch which is
attach today a vehicle and tractor and
moved from site to site. Also included
is an articulated lift assembly and
platform that is used to lift workers
and materials. And before we close out,
heading 8427, there's one related topic
that I wanted to bring to everyone's
attention. That is, there was a
determination issue by the department of
commerce concerning the applicability of
antidumping and counter mailing duties
on certain mobile asset equipment. This
particular determination concerns the
machines that fall within 8427. In
2021, the Department of Commerce
provided notice of the intent to avoid
the -- into the United States. Which
culminated in the issuance of
antidumping case number, 8-570-139 and
case number C570-140. Because this is
under the per view of the Department of
Commerce, we'll go over the order but
note, if we have a specific question,
we'll note that you contact them
directly. For the purpose of today's
presentation, I think it's more
important that everyone is aware of is
case.
The scope of the order covers certain
mobile acts as equipment which is
defined as boom lifts, SDIZer lifts and
sub assemblies thereof. The DOC
message, 1084406 provides the full text
and I encourage everyone to read it.
But for today, we're going to focus on
some key takeaways.
There are few requirements that are
embedded in the scope of this order and
they include a mobile self-propelled or
tow chassis. We looked at both examples
of trucks today. We have determined
that heading 8427 covers both
self-propelled and tow machined.
The trucks also need a lifting device
for mechanically lifting persons, tools
and materials. The language provides
some examples including but not limited
to scissor arm and boom assemblies.
They must be capable of reaching a
working height of 10 feet or more. This
is a very specific requirement that must
be met for machine to fall in the scope
of the order and lastly, it needs a
coupler for attaching it. This shows
mobile act, equipment, sub assemblies,
whether finished, unfinished, assembled
or unassembled and whether the equipment
contains any additional features that
provides for functions beyond the
primary lifting.
Lastly, we also find it includes a
list of codes in the scope border,
however, we recommend and remind the
trade that while the sub headings are
provided for convenience and custom's
purposes, the written description of the
merchandise under investigation is
deposited. If you're entering a good
that goes in one of the lists ACS codes,
it's a good habit, I think, to refer to
the text of it so determine if dumping
applies. But if anyone has specific
questions on the order, we would always
recommend reaching out to the Department
of Commerce.
So to recap, I put a good place to
start is, is the machine self-propelled
or does it need towed? With this
question, we're looking to determine is,
how this machine goes from one location
to another. This helps the
determination at the 6 digit level. The
next question to ask is, is the machine
electrically powered? Is the machine
powered by an electric motor, internal
combustion engine or other power source?
Is it a forklift truck? We looked at
counter balance where there's a
particular break out for it, right? And
then how is the machine designed or how
does it lift or handle the load? Is it
a rider type? Does the machine meet the
definition of work trucks fitted with
handling equipment? If we're uncertain
about the definition of work trucks, we
can look at explanatory notes and past
rulings. And then does the machine
allow to operate, sit, stand or
otherwise ride on during use? And
lastly, is the machine automated? So if
we run through the checklist, it can
help us determine where the machine is
classified or at the very least, it may
help us narrow down the possible sub
headings and get closer to the
classification.
Here are some helpful resources where
you can learn more about the machines to
be discussed today. The first is the
website for OSHA. It focuses on the
safe operation of the machines but also
provides a good description and also
definitions. The second link is the
custom's ruling online search system.
This website, in addition to containing
the ruling to be discussed today, it
also holds a wealth of information on
machines that fall under 8427 and you
can also use it to research rulings on
merchandise, you know, elsewhere. And
this third is a resource of the CBP.gov.
This is website is very helpful for the
community as it includes articles,
links, and other trade related topics.
It can also find a library of recordings
from the CBP Webinar series as well as
many publicized publications.
In this slide is a list of the links
to the source of the photos and images
used during the presentation. So I
wanted to make sure that we give credit
to the creators and owners of each photo
used. Again, the photos and pictures
are meant, not as an endorsement for any
product but we're just included to
provide context in the material. And
here's our contact information. I have
included our e-mail address as well as
the contact information for iris who is
also very knowledgeable and the quickest
and best method is via e-mail. I would
ask, if you reach out, please provide as
much information as possible. This will
give us the best possible, or put us in
the best possible position to answer
your question. Again, I guess that
bring us to the end of the presentation.
We have a little bit of time left over.
If anyone has questions, type them in
the chat box and I can do my best to
answer them.
>> Well, a previous question that came in
and it's been some what answered.
Someone asked, when referencing the
explanatory notes, are they just the
chapter notes and someone said,
explanatory notes are a completely
different book you either purchase or
get an online prescription to?
>> Oh, okay. Thanks, so basically, I
think the answer is correct. The
explanatory notes are a different set of
information and usually broken out to
the specific chapters and headings. So
they are a separate resource. Separate
resource, from the harmonized schedule.
There's several vendors that have them
available. If anyone needs a link,
contact me, send me an e-mail. And I
can send you that information. I can
see someone wants to see slide 41. So
this is slide 41. I see there's a
question, what if the forklifts are
manual? I would say for that, I would
need a very specific example because
usually automated guided vehicles are
self-sufficient. The purpose is to not
need or not require human intervention
so I'm not sure what you mean by manual.
So you're saying used either way. Yes,
I'm not really too sure. I'm not sure
if we're thinking of the same thing.
That might be something, I would need a
specific example on. So you can, if you
could contact me, sends me an e-mail and
I can take a look at it but it may be I
need to submit a ruling request for
that.
Okay, there's a question as to what
type of actions and trends are being
seen in relation to goods coming from
China as it relates to the order? Has
enforcement actions up ticked? That's a
very good question. I think that's a
question that is beyond the scope of
today's Webinar. Today's Webinar is
focusing on the specifics of the
heading. As to the actual enforcement
trend, I'm not sure. I don't have that
information ready but again, you can
send me an e-mail and I'll try to, just
link you up to the correct party that
might be able to help answer that. Oh,
thank you, Sandra. That's the website
for the explanatory notes. Okay, I'm
not seeing anymore questions so I guess,
I guess we can, I can end is here but I
want to thank everyone for taking the
time today, to attend this Webinar and I
also thank you for your attention. So
thank you, everyone!
>> Again, thank you everyone! We hope
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great day. This concludes the Webinar