NCS/ARS/CL/10439

You have applied for the tariff classification of a 25 litres Blow Moulding Machine and a 1.2m Width Wire Mesh Welding Machine imported in fully built unit.

PRODUCT DESCRIPTION AND OPERATION

1. 25L Extrusion Blow Moulding Machine

According to the submitted documentation, the machinery is a 25-litre extrusion blow moulding machine designed for the production of hollow plastic articles, particularly large-capacity containers. It integrates an Extrusion System, Accumulator Die-Head System, Clamping System, Hydraulic System and Electronic Control System into a single production unit.

It operates by heating and melting plastic material, extruding it through a die head to form a tubular parison (an intermediate shape in manufacturing plastics), enclosing the parison within a mould, and introducing compressed air to expand the molten plastic against the mould cavity. The formed article is subsequently cooled, solidified, and removed from the mould.

A. Extrusion System: 
The system consists principally of a specially designed screw, barrel, inverter-controlled drive and automatic temperature-control system. The screw conveys, compresses, mixes and melts the plastic material within the heated barrel before supplying the molten plastic to the die head.

B. Accumulator Die-Head System:
The accumulator die head temporarily stores and rapidly discharges a measured quantity of molten plastic to form the tubular parison, ensuring consistent material delivery suitable for producing large hollow plastic articles.

C. Clamping and Moulding System:
The hydraulic clamping system closes and holds the mould halves around the parison. Compressed air is then introduced into the parison, causing it to expand and conform to the shape of the mould cavity. The article is cooled and solidified before the mould opens for removal.

D. Hydraulic System:
The hydraulic system supplies and controls the force required for the machine's mechanical movements, particularly the clamping and moulding operations. It employs proportional pressure control and hydraulic valves and pumps supplied by SUMITOMO. The proportional hydraulic control allows the pressure and movement of the machine to be regulated accurately and smoothly.

E. Electrical Control System:
A PLC-based control system with a 10-inch touch-screen interface controls the machine's operating sequence, extrusion speed, parison thickness, temperature and other operating parameters. It also provides real-time monitoring, fault diagnosis, alarms and automatic repositioning for the next production cycle.

Accordingly, the machinery is an integrated extrusion blow moulding machine principally designed for manufacturing hollow plastic products.

2. 1.2m Width Wire Mesh Welding Machine

The 1.2m Wire Mesh Welding Machine is an automated machine designed for the manufacture of welded wire mesh from steel or other suitable metal wire. It produces mesh with a maximum width of 1,200 mm and an adjustable length of up to 4,000 mm, using wire diameters ranging from 1.9 mm to 3.5 mm.

The machine integrates wire feeding, straightening, positioning, welding, mesh pulling, edge trimming, cutting and discharge systems, together with an electronic control system.

PRINCIPAL FUNCTION AND OPERATION

The principal function of the machine is to join longitudinal and transverse wires at their intersections by resistance welding to produce rigid welded wire mesh panels.

During operation, longitudinal (warp) wires are supplied from 24 wire reels and passed through straightening rollers into the welding section. The transverse (weft) wires are fed across the longitudinal wires from a turntable/broken wire feeding system. The wires are accurately positioned at predetermined intervals and are then welded together at their intersections by the 24 welding electrodes.

The welding process is supported by water-cooled cast-resin transformers, which supply the electrical energy required for resistance welding. The welded mesh is subsequently pulled forward by a servo motor and precision reducer, which maintains the required mesh dimensions and welding pitch.

The finished mesh passes through the stretching and automatic edge-trimming section, where the edges are finished. It is then cut to the required length and discharged onto mesh trolleys.

Main Components

1. Wire Feeding and Straightening System – supplies and straightens the longitudinal and transverse wires before welding. 
2. Welding Unit – uses 24 welding electrodes, with an upper welding head and high-chromium copper lower welding head, to weld the wires at their intersections. 
3. Transformer System – three water-cooled cast-resin transformers provide the electrical power required for resistance welding.  
4. Mesh Pulling System – servo motor-driven system with precision reducer and pulley-and-rack mechanism advances the welded mesh accurately. 
5. Edge Trimming and Stretching System – straightens and trims the mesh edges to obtain the required finished dimensions. 
6. Mesh Cutting and Discharge System – cuts the mesh to the specified length and transfers the finished panels to discharge trolleys. 
7. Control System – PLC, touch panel, VFD, relays and solenoid valves provide automatic control and monitoring of the machine's operations. 

Accordingly, the machinery is an integrated wire mesh welding machine principally designed for the manufacture of welded metal wire mesh by electrically welding intersecting longitudinal and transverse wires.

TARIFF CLASSIFICATION

Note 5 to Section XVI provides that the expression “machine” means any machine, machinery, plant, equipment, apparatus or appliance cited in the headings of Chapter 84 or 85.

Also, the machines in view comprise various components and systems fitted together to form complete functional units, each designed to perform different operations that contribute to the manufacture of a specific finished product. 

Note 3 to Section XVI provides that composite machines consisting of two or more machines fitted together to form a whole and other machines designed to perform two or more complementary or alternative functions are to be classified according to the machine or component that performs the principal function.

Accordingly, the machines are classified as follows:

1. 25L Extrusion Blow Moulding Machine

The principal function of the machine is the manufacture of hollow plastic articles by the extrusion blow moulding process. It melts and extrudes plastic material into a tubular parison, encloses the parison within a mould and uses compressed air to expand the molten plastic against the mould cavity to form the required article.

The Explanatory Notes to Heading 84.77 include “moulding machines for tyres or other articles of rubber or plastics” within the scope of the heading. Heading 84.77 covers:

“Machinery for working rubber or plastics or for the manufacture of products from these materials, not specified or included elsewhere in this Chapter.”

In view of its principal function and the foregoing provisions, the 25L Extrusion Blow Moulding Machine is appropriately classified under tariff subheading 8477.30.00.00 – Blow moulding machines, at the applicable rate of 5% Customs Duty and 0% VAT, in accordance with the ECOWAS Common External Tariff (CET) and GIR 1 and 6, Notes 3 and 5 to Section XVI, together with the relevant Explanatory Notes.

2. 1.2m Wire Mesh Welding Machine

The principal function of the machine is to manufacture welded metal wire mesh by electrically joining longitudinal and transverse wires at their intersections through resistance welding. The machine automatically feeds, positions and welds the wires, and subsequently pulls, trims and cuts the finished mesh to the required dimensions.

Heading 85.15 covers:

“Electric (including electrically heated gas), laser or other light or photon beam, ultrasonic, electron beam, magnetic pulse or plasma arc soldering, brazing or welding machines and apparatus, whether or not capable of cutting; electric machines and apparatus for hot spraying of metals or cermets.”

Furthermore, Part I(B) of the Explanatory Notes to Heading 85.15 specifically covers machines and apparatus for resistance welding of metal.

Accordingly, the 1.2m Wire Mesh Welding Machine, being an automatic machine principally performing resistance welding of metal wires, is appropriately classified under tariff subheading 8515.31.00.00 – Machines and apparatus for resistance welding of metal: Fully or partly automatic, at the applicable rate of 5% Customs Duty and 0% VAT, in accordance with the ECOWAS Common External Tariff (CET), GIR 1 and 6, Note 5 to Section XVI, and the Explanatory Notes to Heading 85.15, Part I(B).

LEGAL JUSTIFICATION

• GIR 1&6
• Note 3 to section XVI
• Note 5 to section XVI
• Explanatory note to heading 84.77
• Explanatory note to heading 85.15 Part I(B)