Nov 30 CBP Bulletin Ruling Action on Liquid Dispensing Systems
In the November 30, 2011 issue of the U.S. Customs and Border Protection Bulletin (Vol. 45, No. 49), CBP published a notice on its revocation of a ruling and treatment regarding the classification of liquid dispensing systems.
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Revocation Is Effective January 29
The revocation is effective for the listed ruling, as well as any treatment CBP previously accorded to substantially identical transactions, for merchandise entered or withdrawn from warehouse for consumption on or after January 29, 2012.
Liquid Dispensing Systems
| Item: Mechanical liquid dispensing systems. The machines perform high speed, non-contact, low volume pipetting onto plates. The pipetting mechanism allows for the dispensation of volumes in the range of 50nl to 20ul. |
| New ruling: HQ H103965 (dated 11/07/11 (revoked NY N035872) |
| Old HTS/Rate: 8424.89.00, 1.8% (mechanical appliances for dispersing liquids) |
| New HTS/Rate: 8479.89.98, 2.5% (machines and mechanical appliances having individual functions) |
| Reason: The functions performed under heading 8424 - projecting, dispersing, or spraying liquids - are different than the function of dispensing a liquid. CBP states a machine that takes a small pre-selected fixed volume from a larger reservoir and transfers it to a different receiving receptacle performs the function of dispensing and not dispersing. Additionally, the machines' functions are not the same as any of the machines and tools listed in heading 8424 (i.e., fire extinguishers, irrigation sprayers, etc.). CBP also notes it has consistently classified pipetting and other similar systems that dispense liquids under heading 8479. |
(See ITT's Online Archives 11091905 for summary of CBP's proposed revocation.)