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Newly Released CBP HQ Rulings on Feb. 8

The Customs Rulings Online Search System (CROSS) was updated Feb. 8 with the following headquarters rulings (ruling revocations and modifications will be detailed elsewhere in a separate article as they are announced in the Customs Bulletin):

H328959: Request for Reconsideration of NY N327721; Tariff Classification of a Release Coating Line

Ruling: The release coating line is classified under subheading 8479.89.95 as “Machines and mechanical appliances having individual functions, not specified or included elsewhere in this chapter; parts thereof: Other machines and mechanical appliances: Other.” NY N327721 is affirmed.
Issue: What is the proper classification of the release coating line unit?
Item: An interconnection of machines/apparatuses that performs coating of multiple substrates including paper, photo medical paper, PE-coated paper, PET film, and PE-coated PET film, using solvent-based and solvent-free silicone release agents. A release liner is a paper or plastic-based film sheet that is used to carry and prevent the sticky surface from adhering before its use. Silicone release liner substrates are used in a variety of products such as adhesive tapes and labels. The Line is imported unassembled and will include the full machinery line.
Reason: The clearly defined function of this machine is coating of various substrates not the finishing “paper.” Therefore, classification in heading 8439 is inappropriate.
Ruling Date: Jan. 24, 2023