WEBVTT

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>> Good afternoon, my name is Lynn and
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thank you for joining us for the
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machines of heading 8427 Webinar.
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Today's Webinar is part of the 2023
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educations commodity specific Webinar
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series and has an expected duration of
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about one hour. We have a few
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housekeeping rules. Everyone will be
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kept on mute during the presentation so
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we can keep the line clear of any
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background noise. If you have any
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questions or comments, we invite you to
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type those into the chat box at any time
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during the presentation. We will try to
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answer as many questions as we can from
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the chat box at the end of the
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presentation. And the continuing
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education credit code for today's
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Webinar will be placed in the chat box
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throughout the presentation.
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Today's presenter is Mr. Wang, over to
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you.
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>> Mr. Wang: Thank you, Lynn! Good
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afternoon everyone. I hope everyone is
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having a great day and more importantly,
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a better summer. On behalf of the
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office of trade, the office of
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regulations and rulings and the national
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commodities specialist edition, we
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welcome you to today's Webinar. This is
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machines of heading 8427. My name is
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Paul Wong and I'm be introducing an
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introduction and overview of the
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heading. Today's session will last
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approximately one hour with the
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presentation taking roughly 45 minutes
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of that time. To ensure that we able to
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cover all of the information, I do ask
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for your patience. There will be a
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session towards the end of the
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presentation to answer or clarify any
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questions on the material. I would also
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ask that you hold any questions that
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come up during the presentation until
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the end but as always, if you think of
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any questions as we're moving along,
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feel free to type them in the chat box.
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Before we get started, we have a few
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administrative slides to cover.
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We'll start with the mission
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statement. Our mission is to protect
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the American people, safeguard our
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borders and enhance the nation's
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economic prosperity. A mission of the
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office of trade is to facilitate
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legitimate trade and enforce U.S. laws
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and protect the American economy to
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ensure consumer safety and to create a
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level playing field for American
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businesses.
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Please note the disclaimer. This
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Webinar is for general information
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purposes only and is intended as
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guidance. Also, note the line solely on
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the general information on this Webinar
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is not considered reasonable care.
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Recognizing many complicated factors may
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be involved in customs issues and
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importer may wish to obtain guidance
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from private sector experts who
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specialize on custom's matters such as a
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licensed broker, or attorney. This is
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provided solely to provide context for
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the content provided. The audio-visual
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media is for educational purposes only
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and does not represent an endorsement or
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approval of any creators or products.
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Here we have some information about
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CBP's ruling program. Without a doubt,
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you will find we do not cover every
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aspect of each machine. These machines
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are complicated and can have different
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features brand to brand or model to
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model. This is to help with a framework
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of this heading and to provide the
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examples of the machines that fall in
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the sub headings. If you have a
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specific machine and are unsure of the
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classification, we encourage the trade
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to submit a request for a binding rules.
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CBP's website allows the request to be
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filed electronically and the link to
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that web page is found on the slide.
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This slide includes my contact
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information. I'm looking in New York at
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the world trade center in lower
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Manhattan and part of the office of
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NIS103 with the national modties
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specialist edition and there's chapters
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84, 85 and chapter 93. I will also
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share my contact information again
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towards the end of the presentation. So
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don't worry if you didn't get a chance
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to write it down at this time. So as
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previously mentioned, today's topic will
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cover heading 8427. Many of you are
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familiar with these machines. I ask
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that you please bear with me. Today's
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presentation is for those who are
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unfamiliar or even those who need a
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refresher. We'll go over the text of
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the heading and review the explanatory
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notes and go through each of the sub
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headings and look at examples of
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different machines and lastly, we'll
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discuss some helpful tips and things to
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consider when classifying merchandise of
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8427. So on this screen, we have a
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screen shot. It covers forklift trucks,
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other trucks fitted with lifting or
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handling equipment. We'll start with
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the explanatory notes. Also referred to
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as the EN. As we may have heard and
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head in rulings, this description and
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coding system provided a commentary on
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the scope of each heading of the
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harmonized schedule and are generally
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indicative of the general interpretation
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of such headings. The EN, the heading
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8427 start off by saying, with the
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exception of straddle carriers and work
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trucks fitted with a heading covers work
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trucks with fitted and lifting handling
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equipment. This covers KRAENs, mobile
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lifting frames, straddle carriers and
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work trucks fitted with the crane. The
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very last part of this, overlaps with heading
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4827 as they both mention the term work
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trucks. As such, it's important that we
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take time to go over the meaning of this term.
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Nor is it defined in the legal text of the
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harmonized schedule.
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This is specifically and headquarters
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ruling, 9456477 in 1994, this is a
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personal platform on a wooden base. The
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analysis described the term work trucks
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stating that heading 8427 in part covers
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work trucks both self-propelled and
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those not, fitted with lifting or
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handling equipment. The term truck is
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not defined in the legal text of the
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HSTSS or the EN. Keeping this in mind,
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let's go through the explanatory notes.
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The explanatory notes are basically
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separated in two sections. Part A
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covers forklift and other elevating or
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stacking trucks, paragraph 1 covers
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mechanically propelled forklift trucks
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that carry a load on an elevated
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carriage sliding on a vertical mass.
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The lifting mechanism is normally
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situated in front of the driver's seat
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and designed to support the mode during
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movement and lifted for stacking and be
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to place on a vehicle. This group
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basically includes side loading,
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stacking trucks that are designed to
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handle loads and usually equipped with a
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platform to transport over short
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distances. So this is basically
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describing the machines that operate in
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a specific manner.
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Specifically mentioning an elevated
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carriage, slideings on a vertical mass.
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Paragraph two covers other stacking
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machines that are usually mounted on a
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truck and are equipped with a platform
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or fork which can be raised and lowered
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in vertical support by hand or power
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operated wench or rack system. I won't
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spend too much time on this right now
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but we're going to come back to this
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later on.
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Part B of the explanatory notes
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outline other work trucks. This group
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includes trucks with mechanically
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elevating platforms for the maintenance
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of electric cables, public lighting
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systems and et cetera. This describes
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machines such as Ariel lift patterns,
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sometimes referred to as mobile
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elevating platforms. Item two cover LS
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other trucks fitted with lifting or
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handling equipment including those
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specialized for use in particular
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industries. These will be trucks with
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specialized lifting equipment, specific
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to a task or industry, such as the
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textile, ceramic industries. Now we
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have an idea of the types of work trucks
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that fall in this heading, we'll go
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through the sub headings. First two
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indentations at the 6 digit level are
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8427.10 and 8427.20. They cover
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self-propelled trucks with 8427.10
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covered by those with electric motor and
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the other covering the others. Some
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examples are the others, trucks powered
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by hydrogen, gasoline, et cetera. Since
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the sub headings marry each other
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closely, for the purposes of today's
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method, we're going to talk about how
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they operate instead of powered.
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The big take away is for
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classification purposes, you must
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determine how each machine is powered
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before moving on to the 8th digit sub
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heading. The first sub heading we come
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across is writer type counter balance
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fork trucks. Some of you may be
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familiar with these machines and seen
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them during the course of the daily
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lives. If you have ever worked in a
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warehouse, driven past the loading area
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of a big box store or supermarket, you
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may have seen it around.
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To get a better understanding, let's
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break it down to sections so the first
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part of the type says, work trucks must
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be rider type. This refers to a seat,
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sometimes within the cab where the
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operator controls the machine. Writer
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type can mean a type with a platform
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standing like the seater type, the
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platform is within reach of the controls
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to operate the trucks.
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The second part says the trucks are
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counter balanced meaning, using a
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counter weight, opposite of the lifting
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mechanism. In this photo, the lifting
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mechanism is located in the front two
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wheels and the counter weight is
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positioned towards the rear of the truck
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and the very last part says the lifting
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mechanism using forks or steal fingers
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inserted under a load like a pallet or
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bin, hence the name, forklift truck.
00:11:33.769 --> 00:11:35.828
Here we have illustrative
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representations of rider types. One on
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the left is the model design for a
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worker to operate in a seated position.
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The major components of a forklift
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include a mast, operator cab, over head
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guard and forks. The mast is the
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vertical support that allows it to
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raise, lower and put in position. In
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addition to raising and lowering the
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load, it can tilt so the forks can be
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adjusted relative to the ground. The
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forks are usually used to make direct
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contact with the load for transport.
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The operator cab can be opened or
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enclosed. And there's a space where the
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controls are located and also where
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forklift operators sits. You may also
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find many forklifts include an
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overhead's guard whose purpose is to
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protect the operator from falling object
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and consents. On the right, we have an
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illustration of a forklift that is
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operated in a standing position. In
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both pictures, it's located in the front
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of the front axel and just to note,
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there's many variations and rider type
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fork trucks, one example that comes to
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mind is the swing mass forklift for
00:12:44.548 --> 00:12:46.948
those who are familiar. It's basically,
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those kind of trucks that allow the
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mast, you know, usually fitted with
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forks to swing or turn to the side which
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allows the side loading or other
00:12:54.728 --> 00:12:57.108
maneuvers that are suitable for narrow
00:12:57.108 --> 00:13:02.929
isle operations.
00:13:02.929 --> 00:13:03.096

00:13:03.096 --> 00:13:12.888
The next sub heading is 8427.10.80,
00:13:12.888 --> 00:13:15.148
this is described in the statistical
00:13:15.148 --> 00:13:17.148
note 3 of the chapter. If you go to the
00:13:17.148 --> 00:13:18.588
note, you'll see it states for the
00:13:18.588 --> 00:13:20.685
purposes of statistical reporting
00:13:20.685 --> 00:13:34.148
numbers, 8427.10, 8020, 0840, 8070,
00:13:34.148 --> 00:13:38.048
8020, this incorporates a platform
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attached to a lift mechanism, mounted on
00:13:39.963 --> 00:13:41.608
a mobile base for lifting personnel
00:13:41.608 --> 00:13:44.269
tools and materials.
00:13:44.269 --> 00:13:47.968
So let's look at some examples. So
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here we have a photo of the SDIZer lift
00:13:53.628 --> 00:13:55.468
that fits the criteria. From the top
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down, you have a platform that is used
00:13:59.028 --> 00:14:05.328
for that. Next, we have the SDIZ SDER
00:14:05.328 --> 00:14:07.748
arm -- and a mobile base that can
00:14:07.748 --> 00:14:09.288
transport the entire machine from
00:14:09.288 --> 00:14:12.609
location to location.
00:14:12.609 --> 00:14:15.988
In this photo, we have an example of a
00:14:15.988 --> 00:14:20.648
telescoping boom lift and one that is
00:14:20.648 --> 00:14:23.808
lifting personnel, materials and in the
00:14:23.808 --> 00:14:25.403
middle, a lift mechanism which in this
00:14:25.403 --> 00:14:27.928
case is a telescoping boom assembly and
00:14:27.928 --> 00:14:30.215
lastly, we have a mobile base as used to
00:14:30.215 --> 00:14:35.089
support the entire boom lift.
00:14:35.089 --> 00:14:37.275
And here is our last example of an
00:14:37.275 --> 00:14:40.488
Arial work platform. We have a photo of
00:14:40.488 --> 00:14:44.748
a variation of a boom lift, specifically
00:14:44.748 --> 00:14:47.388
articulated boom lift. This differs
00:14:47.388 --> 00:14:50.988
from the telescoping boom lift, the arms
00:14:50.988 --> 00:14:52.989
are JOINLTed and consistent of segments
00:14:52.989 --> 00:14:54.868
making it a better choice if they need
00:14:54.868 --> 00:14:56.895
to maneuver around the obstacle, for
00:14:56.895 --> 00:14:58.828
example. But the telescoping lift has
00:14:58.828 --> 00:15:01.888
all of the features of the aerial flat
00:15:01.888 --> 00:15:04.528
form that goes into 8427. First, it has
00:15:04.528 --> 00:15:07.168
a platform used to lift materials or
00:15:07.168 --> 00:15:09.055
workers and it also has a mechanism that
00:15:09.055 --> 00:15:11.748
is extending from the mobile base. And
00:15:11.748 --> 00:15:13.948
lastly, we have a mobile base that is
00:15:13.948 --> 00:15:15.648
used to transimportant the entire boom
00:15:15.648 --> 00:15:22.269
lift.
00:15:22.269 --> 00:15:25.268
The next sub heading we come across is
00:15:25.268 --> 00:15:29.328
8427.10.80. This provides for other
00:15:29.328 --> 00:15:32.215
operator riding trucks. The trucks
00:15:32.215 --> 00:15:35.595
describe under item A2 of the
00:15:35.595 --> 00:15:37.148
explanatory notes we looked at either
00:15:37.148 --> 00:15:39.628
that fall in this sub heading. So let's
00:15:39.628 --> 00:15:46.028
go back to that note. Basically
00:15:46.028 --> 00:15:48.088
paragraph two says other stacks machines
00:15:48.088 --> 00:15:49.969
usually mounted on a truck and are
00:15:49.969 --> 00:15:51.928
equipped with a platform or fork which
00:15:51.928 --> 00:15:54.588
can be raised and lowered with vertical
00:15:54.588 --> 00:15:57.528
support by hand or power operated wench
00:15:57.528 --> 00:16:02.788
or rack system used for stacking sacks,
00:16:02.788 --> 00:16:05.828
crates, casks, et cetera. So this is
00:16:05.828 --> 00:16:07.268
particular type of lifting truck so
00:16:07.268 --> 00:16:13.749
let's look at an example. Straddle
00:16:13.749 --> 00:16:16.088
trucks or lifts are a common truck used
00:16:16.088 --> 00:16:19.748
to load or unload pallets. Their
00:16:19.748 --> 00:16:21.428
distinguished characteristic is the load
00:16:21.428 --> 00:16:22.488
capacity and stability are determined by
00:16:22.488 --> 00:16:27.588
the out rigger arms, hence the name
00:16:27.588 --> 00:16:29.308
straddle lift. Because of the design,
00:16:29.308 --> 00:16:30.988
it must be contained between the two
00:16:30.988 --> 00:16:33.708
straddles. Just a note of caution,
00:16:33.708 --> 00:16:35.308
straddle lifts like many of the trucks
00:16:35.308 --> 00:16:37.288
in this heading are made in multiple
00:16:37.288 --> 00:16:39.688
configurations. Some may be designed
00:16:39.688 --> 00:16:42.048
for an operator to ride on and some are
00:16:42.048 --> 00:16:44.188
not. The photos in the slide are meant
00:16:44.188 --> 00:16:46.255
to depict types of straddle lifts that
00:16:46.255 --> 00:16:52.049
are operator riding.
00:16:52.049 --> 00:16:55.268
Other examples of operator running
00:16:55.268 --> 00:16:57.268
trucks include reach trucks and order
00:16:57.268 --> 00:16:59.428
pickers. So to the right we have an
00:16:59.428 --> 00:17:01.528
example of a machine advertised as an
00:17:01.528 --> 00:17:04.215
order picker. But an order picker is
00:17:04.215 --> 00:17:06.215
unique, it's able to lift the operator
00:17:06.215 --> 00:17:07.988
to a certain height which allows the
00:17:07.988 --> 00:17:10.648
operator to pick or retrieve items from
00:17:10.648 --> 00:17:15.328
a pallet, shelf or rack. In other
00:17:15.328 --> 00:17:17.808
words, they can pick it as they drive up
00:17:17.808 --> 00:17:18.909
and down the isle.
00:17:18.909 --> 00:17:20.988
A reached truck is a variation of the
00:17:20.988 --> 00:17:22.868
straddle truck in that, it also has a
00:17:22.868 --> 00:17:25.349
mechanism that is capable of extending
00:17:25.349 --> 00:17:27.048
the loads that can be carried away from
00:17:27.048 --> 00:17:30.188
the machine. This will be useful in
00:17:30.188 --> 00:17:31.808
situations, like, for example, where one
00:17:31.808 --> 00:17:33.388
may need to place a load towards the
00:17:33.388 --> 00:17:36.688
rear of a rack such as an double deep
00:17:36.688 --> 00:17:45.528
palette racking system. So next we come
00:17:45.528 --> 00:17:52.250
to 8427.10.40 and 50. These are
00:17:52.250 --> 00:17:54.936
vehicles fitted with lifting or handling
00:17:54.936 --> 00:17:56.708
equipment. So provide a little bit of
00:17:56.708 --> 00:18:00.255
background, some of the earliest guided
00:18:00.255 --> 00:18:02.568
vehicles were industry manufacturing
00:18:02.568 --> 00:18:04.608
handling vehicles that use wires to
00:18:04.608 --> 00:18:06.188
guide them along the warehouse or
00:18:06.188 --> 00:18:08.688
factory. Automated guided vehicles or
00:18:08.688 --> 00:18:12.188
AGV travel along a route demarcated by
00:18:12.188 --> 00:18:16.528
sensors, light beams or induction tape.
00:18:16.528 --> 00:18:18.313
Since they're predictable and their
00:18:18.313 --> 00:18:20.956
speed is relatively low, some argue that
00:18:20.956 --> 00:18:23.128
they are safer to operate and also,
00:18:23.128 --> 00:18:24.875
because they lack an operator, it
00:18:24.875 --> 00:18:27.028
eliminated human errors and makes them
00:18:27.028 --> 00:18:28.629
much more efficient.
00:18:28.629 --> 00:18:31.408
One of the better definitions that I
00:18:31.408 --> 00:18:33.648
can find describe an automated guided
00:18:33.648 --> 00:18:35.728
vehicle as a programmable, mobile
00:18:35.728 --> 00:18:37.903
vehicle used in industrial applications
00:18:37.903 --> 00:18:39.428
to move materials around the
00:18:39.428 --> 00:18:42.108
manufacturing facility. They are fully
00:18:42.108 --> 00:18:44.629
automated and have the ability to make
00:18:44.629 --> 00:18:46.708
decisions such as past selection. The
00:18:46.708 --> 00:18:49.243
method in which each vehicle makes
00:18:49.243 --> 00:18:51.928
decisions can vary. With some methods
00:18:51.928 --> 00:18:54.528
being landmarked based navigation or
00:18:54.528 --> 00:18:57.656
vision based navigation. An automated
00:18:57.656 --> 00:18:59.788
guided vehicle is a broad term that
00:18:59.788 --> 00:19:03.308
covers a number of different machines.
00:19:03.308 --> 00:19:05.403
So I think the big take away here is
00:19:05.403 --> 00:19:07.748
that those that have fallen in heading
00:19:07.748 --> 00:19:13.788
8427 are specifically for vehicles
00:19:13.788 --> 00:19:15.028
fitted with lifted and handling
00:19:15.028 --> 00:19:15.589
equipment.
00:19:15.589 --> 00:19:18.028
Let's take a look at a ruling issued
00:19:18.028 --> 00:19:21.808
in 1992 for such a vehicle. In the New
00:19:21.808 --> 00:19:25.875
York ruling, they reviewed an automated
00:19:25.875 --> 00:19:29.128
guided vehicle that was a machine that
00:19:29.128 --> 00:19:32.215
one, consisted of a steal frame. Two,
00:19:32.215 --> 00:19:34.215
incorporated a lift table to pick up and
00:19:34.215 --> 00:19:37.588
drop off palettes and use electric
00:19:37.588 --> 00:19:40.163
motors for travel. It was fitted with
00:19:40.163 --> 00:19:44.188
an antenna allowed on a wire. The
00:19:44.188 --> 00:19:46.243
vehicle was equipped with another
00:19:46.243 --> 00:19:49.808
antenna and control unit so it could
00:19:49.808 --> 00:19:51.429
send information regarding position, to
00:19:51.429 --> 00:19:53.628
a central control station and receive
00:19:53.628 --> 00:19:54.968
instructions on where to travel to
00:19:54.968 --> 00:19:58.828
reload. CBP classified this sub
00:19:58.828 --> 00:20:03.168
heading, which at the time provided for
00:20:03.168 --> 00:20:05.628
other work trucks fitted with lifting or
00:20:05.628 --> 00:20:09.428
handling equipment. Self-propelled and
00:20:09.428 --> 00:20:25.089
automated guided vehicle.
00:20:25.089 --> 00:20:27.708
It was powered by an electric motor
00:20:27.708 --> 00:20:29.795
and automated in that the vehicle
00:20:29.795 --> 00:20:31.748
followed the wire embedded in the floor
00:20:31.748 --> 00:20:34.215
and that would require a worker to
00:20:34.215 --> 00:20:39.688
operate. So here we have a photo of a
00:20:39.688 --> 00:20:41.168
straddle lift that operates as an
00:20:41.168 --> 00:20:43.488
automated guided vehicle. This
00:20:43.488 --> 00:20:44.948
particular machine has all of the
00:20:44.948 --> 00:20:47.755
characteristics of a straddle lift. It
00:20:47.755 --> 00:20:51.135
has out rigger arms, the lifting
00:20:51.135 --> 00:20:53.372
mechanism between arms and is used to
00:20:53.372 --> 00:20:56.128
lift, load and retrieve palettes but it
00:20:56.128 --> 00:20:58.308
differs in that it lacks a platform for
00:20:58.308 --> 00:21:00.128
the operator to sit and stand on. It's
00:21:00.128 --> 00:21:04.468
designed to be completely automated and
00:21:04.468 --> 00:21:08.348
does not require human intervention.
00:21:08.348 --> 00:21:10.548
The next two sub headings on the
00:21:10.548 --> 00:21:15.128
842710.80 provide for self-propelled,
00:21:15.128 --> 00:21:17.908
powered by other, other. This covers
00:21:17.908 --> 00:21:20.468
the other, or said differently, trucks
00:21:20.468 --> 00:21:22.408
that are neither operator riding or
00:21:22.408 --> 00:21:24.789
automated guided vehicles.
00:21:24.789 --> 00:21:27.748
Upon the piece of machinery that falls
00:21:27.748 --> 00:21:29.535
in this heading is powered jacks.
00:21:29.535 --> 00:21:31.583
Depending on how you are introduced in
00:21:31.583 --> 00:21:33.843
these machines, they can be referred to
00:21:33.843 --> 00:21:36.690
as walking trucks, palette jacks and
00:21:36.690 --> 00:21:43.215
pumps and I'm sure, many other names.
00:21:43.215 --> 00:21:46.028
So on the left here, we have a photo of
00:21:46.028 --> 00:21:48.088
the battery powered electric power jack.
00:21:48.088 --> 00:21:50.528
This unit is self-propelled but notice,
00:21:50.528 --> 00:21:52.188
it does not have a platform for the
00:21:52.188 --> 00:21:54.195
rider to stand on. Also, it is not
00:21:54.195 --> 00:21:59.223
considered an automated guided vehicle
00:21:59.223 --> 00:22:01.148
as it requires them to maneuver and
00:22:01.148 --> 00:22:03.528
operate the machine. An accurate
00:22:03.528 --> 00:22:05.348
description must be a walk behind
00:22:05.348 --> 00:22:09.688
powered jack. This shows a machine that
00:22:09.688 --> 00:22:11.568
features palette wheels, two located
00:22:11.568 --> 00:22:13.808
under the forks used to move it back and
00:22:13.808 --> 00:22:15.928
forwards. There's also a third wheel
00:22:15.928 --> 00:22:17.768
located under the handle which is used
00:22:17.768 --> 00:22:21.336
to push, pull, or steer the truck. And
00:22:21.336 --> 00:22:23.188
similarly on the right, we have a photo
00:22:23.188 --> 00:22:25.243
of a Waccing stacker on the back of a
00:22:25.243 --> 00:22:26.808
lift gate. This is similar to the
00:22:26.808 --> 00:22:28.408
palette jack as it is also
00:22:28.408 --> 00:22:30.468
self-propelled and there's no stand for
00:22:30.468 --> 00:22:32.189
the operator to ride on during
00:22:32.189 --> 00:22:41.469
operation.
00:22:41.469 --> 00:22:43.388
Going on with this, there's some other
00:22:43.388 --> 00:22:45.353
types of machines worth mentioning.
00:22:45.353 --> 00:22:48.408
Straddle lifts or straddle stackers fall
00:22:48.408 --> 00:22:50.868
within the sub heading. They are not to
00:22:50.868 --> 00:22:52.688
be confused with the straddle lifts we
00:22:52.688 --> 00:22:57.128
looked at earlier, they operate to ride
00:22:57.128 --> 00:23:00.135
on the truck. The TRKs that fall under
00:23:00.135 --> 00:23:03.808
this, and 8059 are models and
00:23:03.808 --> 00:23:06.608
configurations which are designed for
00:23:06.608 --> 00:23:08.808
the operator to stand beside while
00:23:08.808 --> 00:23:10.748
operating. These are not to be confused
00:23:10.748 --> 00:23:13.375
with straddle carriers used at ports of
00:23:13.375 --> 00:23:15.349
industry to remove containers.
00:23:15.349 --> 00:23:18.188
Straddle lifts are commonly used in
00:23:18.188 --> 00:23:20.809
warehouses to move and store palettes
00:23:20.809 --> 00:23:23.348
and use indeed areas where the isles are
00:23:23.348 --> 00:23:26.528
narrow. They have forklift that are
00:23:26.528 --> 00:23:28.848
used to lift and raise them. Straddle
00:23:28.848 --> 00:23:31.688
lifts differ from the palette truck we
00:23:31.688 --> 00:23:34.308
just looked at, if they have the ability
00:23:34.308 --> 00:23:36.148
to raise it to a greater height. Just
00:23:36.148 --> 00:23:37.753
keep in mind with all of these sub
00:23:37.753 --> 00:23:39.308
headings, there's other designs and
00:23:39.308 --> 00:23:42.508
types of trucks that fall under, fall
00:23:42.508 --> 00:23:44.948
within the sub heading but, in the
00:23:44.948 --> 00:23:46.408
interest of time, we won't be able to
00:23:46.408 --> 00:23:51.317
cover all of them.
00:23:51.317 --> 00:23:53.628
Since we're on the subject of straddle
00:23:53.628 --> 00:23:55.528
lifts, I just want to spend a little bit
00:23:55.528 --> 00:23:58.028
of time on the term that can be mistaken
00:23:58.028 --> 00:24:03.008
for which is a straddle carrier, they
00:24:03.008 --> 00:24:05.408
are referred to as straddle trucks so it
00:24:05.408 --> 00:24:11.216
can be confusing.
00:24:11.216 --> 00:24:13.255
But they are a type of machine used to
00:24:13.255 --> 00:24:16.968
lift ocean containers by straddling them
00:24:16.968 --> 00:24:20.848
under the frame. So they are found in
00:24:20.848 --> 00:24:24.628
port operations. This includes language
00:24:24.628 --> 00:24:25.836
that states with the exception of
00:24:25.836 --> 00:24:29.375
straddle carriers and work trucks fitted
00:24:29.375 --> 00:24:31.408
with this, this heading covers work
00:24:31.408 --> 00:24:33.375
trucks fitted with lifting or handling
00:24:33.375 --> 00:24:35.443
equipment. Here is a photo of a
00:24:35.443 --> 00:24:37.375
straddle carrier moving the container.
00:24:37.375 --> 00:24:40.008
You can kind of see from the size and
00:24:40.008 --> 00:24:42.068
method of the operation, that these are
00:24:42.068 --> 00:24:44.628
really large pieces of machinery and
00:24:44.628 --> 00:24:46.488
they differ from the machines of heading
00:24:46.488 --> 00:24:58.928
8427. In headquarters ruling, you can
00:24:58.928 --> 00:25:00.848
see it provides an example of the
00:25:00.848 --> 00:25:01.169
machine.
00:25:01.169 --> 00:25:05.503
This looks at a straddle container,
00:25:05.503 --> 00:25:07.943
self-propelled to load, unload, stack
00:25:07.943 --> 00:25:10.028
and transport containers over short
00:25:10.028 --> 00:25:12.508
distances. It consisted of a large
00:25:12.508 --> 00:25:16.028
steel superstructure,/chassis mounted on
00:25:16.028 --> 00:25:19.108
two parallel sets of wheels. This also
00:25:19.108 --> 00:25:22.195
included a superstructure opened at both
00:25:22.195 --> 00:25:25.388
ends that permit the straddle carrier to
00:25:25.388 --> 00:25:28.215
remove it and straddle the container to
00:25:28.215 --> 00:25:29.329
be lifted.
00:25:29.329 --> 00:25:31.628
Lastly, it's on the top for clear
00:25:31.628 --> 00:25:35.068
visibility. There's kind of a lot of
00:25:35.068 --> 00:25:37.255
extrapolating from this ruling but it's
00:25:37.255 --> 00:25:44.288
helpful as it does a good job. Because
00:25:44.288 --> 00:25:47.029
it meets the terms of the heading, this
00:25:47.029 --> 00:25:51.288
is not classified this way. If you
00:25:51.288 --> 00:25:52.788
compare this description that we looked
00:25:52.788 --> 00:25:54.448
at earlier, they are kind of very
00:25:54.448 --> 00:25:56.508
different in the way they operate. They
00:25:56.508 --> 00:25:59.288
are used in different environments.
00:25:59.288 --> 00:26:01.975
Different applications. And they just
00:26:01.975 --> 00:26:03.003
generally look different from one
00:26:03.003 --> 00:26:14.409
another.
00:26:14.409 --> 00:26:16.888
So following this heading, we come to
00:26:16.888 --> 00:26:23.708
8427.20, other than those propelled by a
00:26:23.708 --> 00:26:28.003
motor. We can see from the sub heading
00:26:28.003 --> 00:26:31.408
text from the 6 digit level, it mirrors
00:26:31.408 --> 00:26:34.155
those electrically powered. It has a
00:26:34.155 --> 00:26:36.375
rider type, counter balanced forklift
00:26:36.375 --> 00:26:39.189
trucks, and these tend to operate in the
00:26:39.189 --> 00:26:41.748
same manner as an electrically powered
00:26:41.748 --> 00:26:43.748
model but use a different energy source
00:26:43.748 --> 00:26:45.468
and again, some other types of fuel
00:26:45.468 --> 00:26:58.829
sources are liquid, gas and et cetera.
00:26:58.829 --> 00:27:21.455
This is further broken down to aerial
00:27:21.455 --> 00:27:22.254
work flat forms and others. With this,
00:27:22.254 --> 00:27:22.254
an example is a machine used to use
00:27:22.254 --> 00:27:22.255
combustion engine instead of a motor.
00:27:22.255 --> 00:27:24.356
These require more power. What is note
00:27:24.356 --> 00:27:25.948
to be missing is the sub heading of
00:27:25.948 --> 00:27:27.568
automated guided vehicles with the
00:27:27.568 --> 00:27:29.468
provision for other. I'm not saying
00:27:29.468 --> 00:27:31.148
there aren't any that don't use
00:27:31.148 --> 00:27:33.628
electricity as a fuel source, and I'm
00:27:33.628 --> 00:27:38.048
sure someone in the audience would be
00:27:38.048 --> 00:27:40.108
able find an example of one, but just
00:27:40.108 --> 00:27:41.688
note for classification purposes, they
00:27:41.688 --> 00:27:52.289
are classified under the other.
00:27:52.289 --> 00:27:53.928
Once again, this is similar to the
00:27:53.928 --> 00:27:59.548
end, as the counter parts electrically
00:27:59.548 --> 00:28:02.088
powered. The non electric versions,
00:28:02.088 --> 00:28:04.228
however, are commonly designed to can
00:28:04.228 --> 00:28:05.368
use outdoors and challenging conditions.
00:28:05.368 --> 00:28:08.343
So again, because many of the types of
00:28:08.343 --> 00:28:10.168
work trucks look the same as the
00:28:10.168 --> 00:28:12.508
electric counter parts, I wasn't able to
00:28:12.508 --> 00:28:15.468
find a great deal of examples, however,
00:28:15.468 --> 00:28:20.508
I could find one that has a liquid gas
00:28:20.508 --> 00:28:22.948
cylinder strapped to the rear of the
00:28:22.948 --> 00:28:26.591
vehicle. Although not definitive, if
00:28:26.591 --> 00:28:28.728
you're ever sure of this, the presence
00:28:28.728 --> 00:28:31.128
of a fuel cylinder or tank could be a
00:28:31.128 --> 00:28:36.049
give away that it needs to be looked at
00:28:36.049 --> 00:28:40.296
for 8427.90. So we have reached the
00:28:40.296 --> 00:28:45.288
last six digit break out. This covers
00:28:45.288 --> 00:28:48.468
other trucks. This sub heading is the
00:28:48.468 --> 00:28:51.335
residual heading within 8427 and covers
00:28:51.335 --> 00:28:52.808
those trucks that are not
00:28:52.808 --> 00:28:55.748
self-propelled. It covers a number of
00:28:55.748 --> 00:28:57.255
different and unique machines, not
00:28:57.255 --> 00:29:02.248
covered under 8427 or 8427.20. We will
00:29:02.248 --> 00:29:09.724
take a look at a few examples. Here we
00:29:09.724 --> 00:29:12.348
have a photo of a manual palette jack.
00:29:12.348 --> 00:29:14.288
This is different than what we looked at
00:29:14.288 --> 00:29:18.230
earlier. In that the manual pallet jack
00:29:18.230 --> 00:29:21.289
is not self-propelled but requires you
00:29:21.289 --> 00:29:23.188
to push or pull. The lifting mechanism
00:29:23.188 --> 00:29:24.948
in this example is also manually
00:29:24.948 --> 00:29:28.223
operated. So the tiller functions at
00:29:28.223 --> 00:29:32.628
the pump handle and asks upon the
00:29:32.628 --> 00:29:36.068
hydraulic fluid causing it to lift or
00:29:36.068 --> 00:29:37.849
unload.
00:29:37.849 --> 00:29:39.788
Here we have a different example of a
00:29:39.788 --> 00:29:42.263
manual straddle lift truck. This
00:29:42.263 --> 00:29:44.408
machine is not very complex being it
00:29:44.408 --> 00:29:50.048
lacks an electric motor, but it does
00:29:50.048 --> 00:29:51.588
have a handle and pump that would be
00:29:51.588 --> 00:29:53.608
used to lift the forks and the object
00:29:53.608 --> 00:30:01.908
that is placed upon it. So let's look
00:30:01.908 --> 00:30:03.975
at this a little bit more complex and
00:30:03.975 --> 00:30:06.808
turn it back to the headquarters ruling
00:30:06.808 --> 00:30:11.128
956477. This ruling concerns a personal
00:30:11.128 --> 00:30:13.915
platform described as closed, enclosed
00:30:13.915 --> 00:30:15.468
personal platform attached to an
00:30:15.468 --> 00:30:21.228
articulated hydraulic lifting arm. And
00:30:21.228 --> 00:30:24.188
also included is a battery operated arm
00:30:24.188 --> 00:30:27.208
that can be used using controls to
00:30:27.208 --> 00:30:29.308
maximum working height of 21 feet. The
00:30:29.308 --> 00:30:31.308
personal platform is suitable for aerial
00:30:31.308 --> 00:30:34.328
work, either inside or outside. It was
00:30:34.328 --> 00:30:40.388
not self-propelled and must be towed by
00:30:40.388 --> 00:30:42.569
a car between job sites.
00:30:42.569 --> 00:30:46.068
First, they stated that this heading
00:30:46.068 --> 00:30:48.263
covers work trucks, both self-propelled
00:30:48.263 --> 00:30:50.388
and those not self-propelled. Fitted
00:30:50.388 --> 00:30:52.510
with lifting or handling equipment.
00:30:52.510 --> 00:30:54.348
Secondly, they stated that the term
00:30:54.348 --> 00:30:55.968
truck is not defined in the legal text
00:30:55.968 --> 00:31:00.868
of the HCS nor in the EN. However, it's
00:31:00.868 --> 00:31:03.296
common meeting was broad enough to
00:31:03.296 --> 00:31:06.208
encompass wheeled frames for moving
00:31:06.208 --> 00:31:08.128
heavy objects and third, the EN
00:31:08.128 --> 00:31:09.669
described trucks with mechanically
00:31:09.669 --> 00:31:11.509
elevating platforms for the maintenance
00:31:11.509 --> 00:31:13.629
of electric cables, public lighting
00:31:13.629 --> 00:31:15.748
systems and et cetera. So taking
00:31:15.748 --> 00:31:18.168
everything together, the personal
00:31:18.168 --> 00:31:21.728
platform at the terms of heading 8427 as
00:31:21.728 --> 00:31:24.035
a work truck, it was fitted with lifting
00:31:24.035 --> 00:31:27.188
equipment and it was classified under
00:31:27.188 --> 00:31:32.819
8427.90.
00:31:32.819 --> 00:31:36.548
Here we have another ruling, New York
00:31:36.548 --> 00:31:49.488
E84483. This ruling looked at the DINO
00:31:49.488 --> 00:31:53.003
lift. This consists of a two wheel
00:31:53.003 --> 00:31:56.589
trailer chassis, four out riggers,
00:31:56.589 --> 00:31:59.915
articulated arm with a cage. It
00:31:59.915 --> 00:32:04.224
contained a hitch that allows it to be
00:32:04.224 --> 00:32:07.255
towed from job site to job site. This
00:32:07.255 --> 00:32:11.568
is a sub heading 8427.90. The reason
00:32:11.568 --> 00:32:13.575
being it was fitted with lifting
00:32:13.575 --> 00:32:15.475
equipment, at the same time, still need
00:32:15.475 --> 00:32:17.748
today be towed from job site to job
00:32:17.748 --> 00:32:21.828
site. I wasn't able to find a photo of
00:32:21.828 --> 00:32:24.248
the DINO lift but here's a picture of
00:32:24.248 --> 00:32:25.888
what I imagine is similar to the lift
00:32:25.888 --> 00:32:27.488
described in the headquarters in New
00:32:27.488 --> 00:32:33.129
York ruling. It has a hitch which is
00:32:33.129 --> 00:32:34.572
attach today a vehicle and tractor and
00:32:34.572 --> 00:32:36.628
moved from site to site. Also included
00:32:36.628 --> 00:32:38.936
is an articulated lift assembly and
00:32:38.936 --> 00:32:41.724
platform that is used to lift workers
00:32:41.724 --> 00:32:49.688
and materials. And before we close out,
00:32:49.688 --> 00:32:52.948
heading 8427, there's one related topic
00:32:52.948 --> 00:32:54.543
that I wanted to bring to everyone's
00:32:54.543 --> 00:32:58.944
attention. That is, there was a
00:32:58.944 --> 00:33:01.628
determination issue by the department of
00:33:01.628 --> 00:33:03.668
commerce concerning the applicability of
00:33:03.668 --> 00:33:06.188
antidumping and counter mailing duties
00:33:06.188 --> 00:33:09.769
on certain mobile asset equipment. This
00:33:09.769 --> 00:33:12.412
particular determination concerns the
00:33:12.412 --> 00:33:15.108
machines that fall within 8427. In
00:33:15.108 --> 00:33:18.988
2021, the Department of Commerce
00:33:18.988 --> 00:33:22.003
provided notice of the intent to avoid
00:33:22.003 --> 00:33:27.721
the -- into the United States. Which
00:33:27.721 --> 00:33:29.948
culminated in the issuance of
00:33:29.948 --> 00:33:36.008
antidumping case number, 8-570-139 and
00:33:36.008 --> 00:33:39.655
case number C570-140. Because this is
00:33:39.655 --> 00:33:42.961
under the per view of the Department of
00:33:42.961 --> 00:33:44.528
Commerce, we'll go over the order but
00:33:44.528 --> 00:33:46.348
note, if we have a specific question,
00:33:46.348 --> 00:33:47.888
we'll note that you contact them
00:33:47.888 --> 00:33:49.406
directly. For the purpose of today's
00:33:49.406 --> 00:33:51.008
presentation, I think it's more
00:33:51.008 --> 00:33:55.128
important that everyone is aware of is
00:33:55.128 --> 00:33:58.189
case.
00:33:58.189 --> 00:34:00.449
The scope of the order covers certain
00:34:00.449 --> 00:34:02.075
mobile acts as equipment which is
00:34:02.075 --> 00:34:07.428
defined as boom lifts, SDIZer lifts and
00:34:07.428 --> 00:34:11.409
sub assemblies thereof. The DOC
00:34:11.409 --> 00:34:15.332
message, 1084406 provides the full text
00:34:15.332 --> 00:34:17.455
and I encourage everyone to read it.
00:34:17.455 --> 00:34:20.275
But for today, we're going to focus on
00:34:20.275 --> 00:34:22.389
some key takeaways.
00:34:22.389 --> 00:34:24.003
There are few requirements that are
00:34:24.003 --> 00:34:25.995
embedded in the scope of this order and
00:34:25.995 --> 00:34:30.849
they include a mobile self-propelled or
00:34:30.849 --> 00:34:33.848
tow chassis. We looked at both examples
00:34:33.848 --> 00:34:35.348
of trucks today. We have determined
00:34:35.348 --> 00:34:37.569
that heading 8427 covers both
00:34:37.569 --> 00:34:40.956
self-propelled and tow machined.
00:34:40.956 --> 00:34:43.068
The trucks also need a lifting device
00:34:43.068 --> 00:34:45.543
for mechanically lifting persons, tools
00:34:45.543 --> 00:34:48.008
and materials. The language provides
00:34:48.008 --> 00:34:50.628
some examples including but not limited
00:34:50.628 --> 00:34:55.148
to scissor arm and boom assemblies.
00:34:55.148 --> 00:34:56.568
They must be capable of reaching a
00:34:56.568 --> 00:34:58.548
working height of 10 feet or more. This
00:34:58.548 --> 00:35:00.068
is a very specific requirement that must
00:35:00.068 --> 00:35:03.768
be met for machine to fall in the scope
00:35:03.768 --> 00:35:09.688
of the order and lastly, it needs a
00:35:09.688 --> 00:35:13.115
coupler for attaching it. This shows
00:35:13.115 --> 00:35:15.288
mobile act, equipment, sub assemblies,
00:35:15.288 --> 00:35:18.528
whether finished, unfinished, assembled
00:35:18.528 --> 00:35:21.268
or unassembled and whether the equipment
00:35:21.268 --> 00:35:22.929
contains any additional features that
00:35:22.929 --> 00:35:24.608
provides for functions beyond the
00:35:24.608 --> 00:35:31.669
primary lifting.
00:35:31.669 --> 00:35:33.915
Lastly, we also find it includes a
00:35:33.915 --> 00:35:35.728
list of codes in the scope border,
00:35:35.728 --> 00:35:37.708
however, we recommend and remind the
00:35:37.708 --> 00:35:39.977
trade that while the sub headings are
00:35:39.977 --> 00:35:42.008
provided for convenience and custom's
00:35:42.008 --> 00:35:44.668
purposes, the written description of the
00:35:44.668 --> 00:35:47.708
merchandise under investigation is
00:35:47.708 --> 00:35:49.515
deposited. If you're entering a good
00:35:49.515 --> 00:35:52.048
that goes in one of the lists ACS codes,
00:35:52.048 --> 00:35:54.668
it's a good habit, I think, to refer to
00:35:54.668 --> 00:35:57.288
the text of it so determine if dumping
00:35:57.288 --> 00:35:59.808
applies. But if anyone has specific
00:35:59.808 --> 00:36:03.223
questions on the order, we would always
00:36:03.223 --> 00:36:17.408
recommend reaching out to the Department
00:36:17.408 --> 00:36:17.650
of Commerce.
00:36:17.650 --> 00:36:21.008
So to recap, I put a good place to
00:36:21.008 --> 00:36:23.262
start is, is the machine self-propelled
00:36:23.262 --> 00:36:25.728
or does it need towed? With this
00:36:25.728 --> 00:36:27.808
question, we're looking to determine is,
00:36:27.808 --> 00:36:32.258
how this machine goes from one location
00:36:32.258 --> 00:36:34.323
to another. This helps the
00:36:34.323 --> 00:36:42.208
determination at the 6 digit level. The
00:36:42.208 --> 00:36:44.388
next question to ask is, is the machine
00:36:44.388 --> 00:36:46.488
electrically powered? Is the machine
00:36:46.488 --> 00:36:51.748
powered by an electric motor, internal
00:36:51.748 --> 00:36:54.108
combustion engine or other power source?
00:36:54.108 --> 00:36:57.728
Is it a forklift truck? We looked at
00:36:57.728 --> 00:36:58.988
counter balance where there's a
00:36:58.988 --> 00:37:00.508
particular break out for it, right? And
00:37:00.508 --> 00:37:03.368
then how is the machine designed or how
00:37:03.368 --> 00:37:05.548
does it lift or handle the load? Is it
00:37:05.548 --> 00:37:09.408
a rider type? Does the machine meet the
00:37:09.408 --> 00:37:12.008
definition of work trucks fitted with
00:37:12.008 --> 00:37:14.208
handling equipment? If we're uncertain
00:37:14.208 --> 00:37:15.948
about the definition of work trucks, we
00:37:15.948 --> 00:37:18.448
can look at explanatory notes and past
00:37:18.448 --> 00:37:20.968
rulings. And then does the machine
00:37:20.968 --> 00:37:22.788
allow to operate, sit, stand or
00:37:22.788 --> 00:37:24.948
otherwise ride on during use? And
00:37:24.948 --> 00:37:28.988
lastly, is the machine automated? So if
00:37:28.988 --> 00:37:30.568
we run through the checklist, it can
00:37:30.568 --> 00:37:32.568
help us determine where the machine is
00:37:32.568 --> 00:37:34.775
classified or at the very least, it may
00:37:34.775 --> 00:37:37.115
help us narrow down the possible sub
00:37:37.115 --> 00:37:38.788
headings and get closer to the
00:37:38.788 --> 00:37:43.729
classification.
00:37:43.729 --> 00:37:45.988
Here are some helpful resources where
00:37:45.988 --> 00:37:49.048
you can learn more about the machines to
00:37:49.048 --> 00:37:54.568
be discussed today. The first is the
00:37:54.568 --> 00:37:56.568
website for OSHA. It focuses on the
00:37:56.568 --> 00:37:58.168
safe operation of the machines but also
00:37:58.168 --> 00:38:03.335
provides a good description and also
00:38:03.335 --> 00:38:05.388
definitions. The second link is the
00:38:05.388 --> 00:38:07.068
custom's ruling online search system.
00:38:07.068 --> 00:38:10.068
This website, in addition to containing
00:38:10.068 --> 00:38:12.068
the ruling to be discussed today, it
00:38:12.068 --> 00:38:14.048
also holds a wealth of information on
00:38:14.048 --> 00:38:16.449
machines that fall under 8427 and you
00:38:16.449 --> 00:38:18.515
can also use it to research rulings on
00:38:18.515 --> 00:38:24.789
merchandise, you know, elsewhere. And
00:38:24.789 --> 00:38:26.888
this third is a resource of the CBP.gov.
00:38:26.888 --> 00:38:30.208
This is website is very helpful for the
00:38:30.208 --> 00:38:32.408
community as it includes articles,
00:38:32.408 --> 00:38:34.720
links, and other trade related topics.
00:38:34.720 --> 00:38:37.648
It can also find a library of recordings
00:38:37.648 --> 00:38:40.108
from the CBP Webinar series as well as
00:38:40.108 --> 00:38:46.169
many publicized publications.
00:38:46.169 --> 00:38:47.948
In this slide is a list of the links
00:38:47.948 --> 00:38:49.648
to the source of the photos and images
00:38:49.648 --> 00:38:51.388
used during the presentation. So I
00:38:51.388 --> 00:38:53.155
wanted to make sure that we give credit
00:38:53.155 --> 00:38:56.208
to the creators and owners of each photo
00:38:56.208 --> 00:38:58.728
used. Again, the photos and pictures
00:38:58.728 --> 00:39:01.195
are meant, not as an endorsement for any
00:39:01.195 --> 00:39:02.808
product but we're just included to
00:39:02.808 --> 00:39:08.848
provide context in the material. And
00:39:08.848 --> 00:39:10.928
here's our contact information. I have
00:39:10.928 --> 00:39:13.208
included our e-mail address as well as
00:39:13.208 --> 00:39:16.728
the contact information for iris who is
00:39:16.728 --> 00:39:19.235
also very knowledgeable and the quickest
00:39:19.235 --> 00:39:24.668
and best method is via e-mail. I would
00:39:24.668 --> 00:39:26.488
ask, if you reach out, please provide as
00:39:26.488 --> 00:39:28.768
much information as possible. This will
00:39:28.768 --> 00:39:33.270
give us the best possible, or put us in
00:39:33.270 --> 00:39:34.428
the best possible position to answer
00:39:34.428 --> 00:39:41.328
your question. Again, I guess that
00:39:41.328 --> 00:39:46.628
bring us to the end of the presentation.
00:39:46.628 --> 00:39:49.689
We have a little bit of time left over.
00:39:49.689 --> 00:39:52.003
If anyone has questions, type them in
00:39:52.003 --> 00:39:53.828
the chat box and I can do my best to
00:39:53.828 --> 00:39:58.710
answer them.
00:39:58.710 --> 00:40:00.114
>> Well, a previous question that came in
00:40:00.114 --> 00:40:01.635
and it's been some what answered.
00:40:01.635 --> 00:40:04.548
Someone asked, when referencing the
00:40:04.548 --> 00:40:06.855
explanatory notes, are they just the
00:40:06.855 --> 00:40:08.388
chapter notes and someone said,
00:40:08.388 --> 00:40:09.848
explanatory notes are a completely
00:40:09.848 --> 00:40:11.475
different book you either purchase or
00:40:11.475 --> 00:40:14.609
get an online prescription to?
00:40:14.609 --> 00:40:17.168
>> Oh, okay. Thanks, so basically, I
00:40:17.168 --> 00:40:20.109
think the answer is correct. The
00:40:20.109 --> 00:40:28.309
explanatory notes are a different set of
00:40:28.309 --> 00:40:29.965
information and usually broken out to
00:40:29.965 --> 00:40:32.568
the specific chapters and headings. So
00:40:32.568 --> 00:40:35.168
they are a separate resource. Separate
00:40:35.168 --> 00:40:43.695
resource, from the harmonized schedule.
00:40:43.695 --> 00:40:46.568
There's several vendors that have them
00:40:46.568 --> 00:40:48.488
available. If anyone needs a link,
00:40:48.488 --> 00:40:55.930
contact me, send me an e-mail. And I
00:40:55.930 --> 00:40:57.328
can send you that information. I can
00:40:57.328 --> 00:41:04.268
see someone wants to see slide 41. So
00:41:04.268 --> 00:41:12.768
this is slide 41. I see there's a
00:41:12.768 --> 00:41:16.328
question, what if the forklifts are
00:41:16.328 --> 00:41:19.708
manual? I would say for that, I would
00:41:19.708 --> 00:41:24.608
need a very specific example because
00:41:24.608 --> 00:41:30.068
usually automated guided vehicles are
00:41:30.068 --> 00:41:31.988
self-sufficient. The purpose is to not
00:41:31.988 --> 00:41:35.068
need or not require human intervention
00:41:35.068 --> 00:41:36.588
so I'm not sure what you mean by manual.
00:41:36.588 --> 00:41:58.529
So you're saying used either way. Yes,
00:41:58.529 --> 00:42:02.568
I'm not really too sure. I'm not sure
00:42:02.568 --> 00:42:04.049
if we're thinking of the same thing.
00:42:04.049 --> 00:42:06.854
That might be something, I would need a
00:42:06.854 --> 00:42:09.928
specific example on. So you can, if you
00:42:09.928 --> 00:42:14.144
could contact me, sends me an e-mail and
00:42:14.144 --> 00:42:16.109
I can take a look at it but it may be I
00:42:16.109 --> 00:42:17.668
need to submit a ruling request for
00:42:17.668 --> 00:42:23.209
that.
00:42:23.209 --> 00:42:24.768
Okay, there's a question as to what
00:42:24.768 --> 00:42:27.068
type of actions and trends are being
00:42:27.068 --> 00:42:29.348
seen in relation to goods coming from
00:42:29.348 --> 00:42:36.728
China as it relates to the order? Has
00:42:36.728 --> 00:42:41.895
enforcement actions up ticked? That's a
00:42:41.895 --> 00:42:43.235
very good question. I think that's a
00:42:43.235 --> 00:42:45.288
question that is beyond the scope of
00:42:45.288 --> 00:42:50.701
today's Webinar. Today's Webinar is
00:42:50.701 --> 00:42:52.120
focusing on the specifics of the
00:42:52.120 --> 00:42:59.048
heading. As to the actual enforcement
00:42:59.048 --> 00:43:01.490
trend, I'm not sure. I don't have that
00:43:01.490 --> 00:43:02.730
information ready but again, you can
00:43:02.730 --> 00:43:04.924
send me an e-mail and I'll try to, just
00:43:04.924 --> 00:43:07.050
link you up to the correct party that
00:43:07.050 --> 00:43:12.895
might be able to help answer that. Oh,
00:43:12.895 --> 00:43:14.456
thank you, Sandra. That's the website
00:43:14.456 --> 00:43:39.908
for the explanatory notes. Okay, I'm
00:43:39.908 --> 00:43:41.848
not seeing anymore questions so I guess,
00:43:41.848 --> 00:43:45.888
I guess we can, I can end is here but I
00:43:45.888 --> 00:43:47.408
want to thank everyone for taking the
00:43:47.408 --> 00:43:51.188
time today, to attend this Webinar and I
00:43:51.188 --> 00:43:52.748
also thank you for your attention. So
00:43:52.748 --> 00:43:58.971
thank you, everyone!
00:43:58.971 --> 00:44:00.348
>> Again, thank you everyone! We hope
00:44:00.348 --> 00:44:02.308
that you found today's Webinar
00:44:02.308 --> 00:44:04.408
informative. The continuing education
00:44:04.408 --> 00:44:06.608
credit code was placed in the Webex chat
00:44:06.608 --> 00:44:08.695
box throughout the presentation. It
00:44:08.695 --> 00:44:10.968
will be e-mailed to the participants
00:44:10.968 --> 00:44:13.855
within 48 hours. Today's Webinar will
00:44:13.855 --> 00:44:17.508
be posted on CBP.gov under the trade out
00:44:17.508 --> 00:44:22.088
reach Webinars in the coming weeks.

00:44:23.548 --> 00:44:23.548
great day. This concludes the Webinar