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Customs Ruling NY N266946 - The tariff classification of the CreoPop 3D Printing Set from China

CLA-2-84:OT:RR:NC:N1:104

Mr. ZuoZhao Feng
Shenzhen Jisong Electronics Co., Ltd.
401 Fuyuan Building
Fanshen Road, 45 Block
Baoan District, Shenzhen
China 518133

RE: The tariff classification of the CreoPop 3D Printing Set from China

Dear Mr. Zuo:

In your letter dated July 14, 2015 you requested a tariff classification ruling. Sample will be returned to you as per your request.

The CreoPop 3D Printing Pen Set features a lithium-ion powered portable 3D printing pen. The pen has a built-in rechargeable 1.5 Wh, 400mAh, 3.7V Li-Polymer battery which allows a person to operate the pen for one hour on a single charge. The 3D Pen has a battery indicator light that will turn on when the battery becomes low so that a person can recharge it using the included charging cable. Users of the CeoPop 3D Pen are able to draw 2D and 3D designs in a freestyle freehand format without being connected to a printer. No software is needed to print designs. The CreoPop pen extrudes light sensitive ink called photopolymers which are solidified by the LED lights surrounding the nozzle of the pen. There is no hot or melting plastic or unpleasant smell. A user just has to push a button and start drawing. Cartridges can be easily changed to create more complex designs. The CreoPop set is imported packaged for retail sale in a retail box. The set contains: One CreoPop 3D Printing Pen CreoPop Ink Box containing Three Ink Cartridges and an Ink Information Flyer One Instruction Manual and One Quick Start Guide One Mini-USB cable General Rule of Interpretation (GRI) 1, Harmonized Tariff Schedule of the United States (HTSUS), states in part that for legal purposes, classification shall be determined according to the terms of the headings and any relative section or chapter notes. Goods that are, prima facie, classifiable under two or more headings, are classifiable in accordance with GRI 3, HTSUS.

All the components are packed in a box that features a specially designed foam insert with cutouts for holding the set’s components. No additional articles will be added to the set subsequent to importation. In view of these facts, consideration was given to General Rule of Interpretation 3(b) (“GRI 3(b)”). Explanatory Note X to GRI 3(b) provides that for the purpose of this rule, the term “goods put up in sets for retail sale” shall be taken to mean goods which: (a) consist of at least two different articles, which are, prima facie, classifiable in different headings, (b) consist of products or articles put up together to meet a specific activity; and (c) are put up in a manner suitable for sale directly to users without repackaging. The instant set consists of at least two different articles that are, prima facie, classifiable in different subheadings. The set consists of articles put up together to carry out a specific activity, i.e., 3D printing. Finally, the components are put up in a manner suitable for sale directly to users without repacking. Therefore, the set in question is within the term "goods put up in sets for retail sale." GRI 3(b) states in part that goods put up in sets for retail sale, which cannot be classified by reference to 3(a), are to be classified as if they consisted of the component which gives them their essential character. In this office’s opinion, the 3D printing pen provides the essential character to the set.In accordance with GRI 3(b), the applicable subheading for the CreoPop 3D Printing Pen Set, as described above, will be 8477.80.0000, HTSUS, which provides for “Machinery for working rubber or plastics or for the manufacture of products from these materials, not specified or included elsewhere in this chapter; parts thereof: Other machinery”. The rate of duty will be 3.1 percent ad valorem.

Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.

In your original submission, you also requested a ruling on whether the proposed marking “Assembled in China” found on the set’s retail box is an acceptable country of origin marking for imported set.

The marking statute, section 304, Tariff Act of 1930, as amended (19 U.S.C. 1304), provides that, unless excepted, every article of foreign origin (or its container) imported into the U.S. shall be marked in a conspicuous place as legibly, indelibly and permanently as the nature of the article (or its container) will permit, in such a manner as to indicate to the ultimate purchaser in the U.S. the English name of the country of origin of the article.

As provided in section 134.41(b), Customs Regulations (19 CFR 134.41(b)), the country of origin marking is considered conspicuous if the ultimate purchaser in the U.S. is able to find the marking easily and read it without strain.

With regard to the permanency of a marking, section 134.41(a), Customs Regulations (19 CFR 134. 41(a)), provides that as a general rule marking requirements are best met by marking worked into the article at the time of manufacture. For example, it is suggested that the country of origin on metal articles be die sunk, molded in, or etched. However, section 134.44, Customs Regulations (19 CFR 134.44), generally provides that any marking that is sufficiently permanent so that it will remain on the article until it reaches the ultimate purchaser unless deliberately removed is acceptable.

In this case, we find that we need additional information to make a marking determination. Please submit the following information – Are all the articles of the boxed set manufactured in China? If not, provide the country of origin for each non-Chinese article. Are all the pen’s components manufactured in China or is the pen assembled in China from non-Chinese components? Submitted sample shows “Assembled in China”. What specific assembly work is performed in China? Is it the production of the pen itself or only the placement of the various articles (pen, inks, instruction manual, quick start guide and cable) into the retail box?

This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C. F.R. 177).

A copy of the ruling or the control number indicated above should be provided with the entry documents filed at the time this merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist Patricia O’Donnell at [email protected]

Sincerely,

Gwenn Klein Kirschner
Director
National Commodity Specialist Division

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3D Printing Pen - D9 1.75mm ABS/PLA

Good day!
I propose for your judgment a review of 3D pens, such devices have been described here more than once, but it seems that this particular model did not exist.
Of the features, they promise the possibility of working with plastic of two types ABS / PLA.

Features:

  • Color: White
  • Power supply: 5V / 2A
  • Adapter type: US / EU plug
  • Print material: 1.75mm ABS/PLA
  • Print temperature: ABS (210-235℃), PLA (165-200℃)
  • Nozzle: 0.7mm
  • Feed speed: adjustable 3 speeds
  • 1 x EU / US power adapter
  • 1 x Pen stand
  • 3 skeins of PLA filament
  • 3 paper stencils for sampling about 10 meters of each color.

    Description of the contents on the box in a bunch of languages ​​other than Russian.

    More about what's inside the box:
    Power supply 5 V. 2 A. with output to a USB connector so that the pen can also be used from a regular PowerBank, consumption during the initial heating of the nozzle does not exceed 1.7-1.8A, during operation it is even less around 1.5A with the engine running. Wire included 1.2m.

    The pen stand, frankly flimsy and not very comfortable, the pen is constantly trying to fall off it.


    The pen comes with three rolls of PLA plastic. While the plastic in the coils is very hard and hard, it seems that it will break rather than bend, but after leaving the handle it becomes much softer even after cooling.


    The manufacturer also included three stencils in the kit, on which you can draw the first masterpieces.

    And so that the stencils do not deteriorate and the masterpiece can be repeated several times, the kit comes with something most like a sheet of plastic. As I understand it, in theory, you need to cover the stencil with this leaf and draw already on it. Again, in theory, the plastic should stick well to this leaflet and easily separate from it.

    About handle:
    The pen itself is made of white glossy plastic and is shaped like something out of a space movie.
    Length approx. 20 cm.

    The thickness in the area of ​​the fingers is about 2.5 cm. There is a significant thickening in the back, in which the plastic feed mechanism is located.

    In the nozzle area, the handle is made of black matte plastic, which heats up quite noticeably during operation, the nozzle itself is most likely ceramic, it was originally white, but during use it changed color to yellowish.

    The handle is controlled by two buttons and one three-position switch.
    On the right side of the handle is the On/Off button, to remove the plastic from the handle, the button must be pressed and held. After the plastic comes out, the pen automatically turns off and, if you want to continue drawing with a new color, you have to turn it on again and wait for the nozzle to warm up. The switch is responsible for the plastic feed speed, there are three feed speeds to choose from.

    On the left side of the handle under the thumb is a button responsible for the supply of plastic. Pressed once plastic went, pressed again stopped. The same button is used to fill the plastic in the pen.

    On the back end there is a socket for connecting the power cable and a hole for refilling plastic.

    Trying to draw:
    After turning on the handle with the button, the orange LED lights up and the nozzle starts heating.

    After warming up, the LED will turn green. You can insert the plastic and press the feed button, after the plastic comes out of the nozzle, press the button again, the pen is ready to work.

    Small deviation
    After the very first attempts to draw on a stencil, it turned out that something translucent, according to which they offer to draw very little for this, is suitable. PLA sticks to this sheet so it's almost impossible to tear off, and if you paint with a thin layer, then it's impossible to tear off the parts whole. ABS plastic behaves a little better, but also sticks a lot. And most importantly, after the first use, the sheet was very much warped and it became very inconvenient to use it in the future.

    But I wanted to draw, so different options were used. Baking paper, plastic sticks a little worse, but it is too thin when parts are separated, it often tears, the second minus, it is sold in narrow rolls, it takes a long time to level it. Cellophane for baking plastic sticks to it very badly, and the kiss itself becomes matte from heating and gathers like an accordion. Tracing paper for laser printers showed itself best of all, it very much resembles what the seller put in the kit, but at the same time, PLA is separated from it in just one movement, and ABS generally falls off by itself.
    This is how the tracing paper leaf looks after it has been used.

    After filling the pen, you can apply a stencil and start drawing, when using PLA from the kit, the smell of burnt sugar spreads around the room, it reminds of childhood, how they tried to cook caramel on the stove.

    After separation, a little more plastic for assembly and a fashion accessory is obtained.

    Well, or here's a bike.

    And adding a guitar to it, you can go on a sortie.

    Comparison of plastic feed speed.

    By the way, it took me 10 minutes 25 seconds to get the glasses, and the pen managed to eat 284 mA during this time, which gives an average current of 1700 mA, a 10000mA power bank should be enough for 4-5 hours of entertainment.

    ABS work
    In my city I bought a set of ABS plastic for the handle, fifteen colors, ten meters of each color. At the first use, I sat down to read the instructions, but how, in fact, to switch the handle to work with ABS, alas, there is no mention of this in the instructions. Or the pen controller somehow understands what is filled in it, for example, by the force on the extruder motor when trying to push ABS through an insufficiently hot nozzle. But most likely, the handle initially keeps the nozzle hotter than necessary for PLA and perhaps a little less hot than necessary for ABS, such a universal middle and so it works with both types of plastic. I would like to believe in the first option, but I think that the second is more likely.
    In any case, ABS also melts and in my opinion it’s not bad at all, although the smell is not very pleasant, although not as strong as from PLA, so you can put up with it. Or again, PowerBank and the street.
    And yes, I'm still that sculptor :)

    But the work of a real master, after which you immediately understand that such a pen is not a toy at all, inserting a video is prohibited by the author, so just a link.

    The inner world of a pen.
    Disassembly of the handle is more than simple. The day of the beginning, you need to unscrew a couple of screws that hold the casing around the nozzle, and then a few latches around the perimeter and the handle is divided into two halves.

    Inside there is a small control scarf, according to tradition, the manufacturer has erased the markings on the controller.

    The hot end of the pen itself, what a 3D printer would call the HotEnd. It is connected to the board with four contacts, a pair to the heater and a pair to the temperature sensor. Plastic growths are visible around the contacts, it seems that the manufacturer made a poor seam between the ceramic nozzle and the tube through which the plastic is fed.

    By the way, a steel tube for plastic comes out of the head itself, which then turns into a plastic one, and the plastic one, in turn, inside the handle again enters the steel casing.

    And this is how the head connects to the main board of the handle.

    All gears in the extruder are made of metal, so the feed is pretty reliable.

    After the plastic comes out of the handle, the steps from the feed gear are clearly visible on it.

    Video of unpacking and pen test :)

    Small conclusion.
    After unpacking, I turned it on to try what it is and whether it works, and sat drawing for about three hours, the time flew by like one minute. So I can say with confidence that this is a very good entertainment not only for children, but also for adult uncles and aunts. Of the minuses, it is probably worth noting the not entirely understood mode of operation with two plastics in this sample, and the prices, not only for the pens themselves, but also for PLA plastic, offline are about twice as expensive as ABS. At the same time, ABS has a rather noticeable smell and it is undesirable to use it without good ventilation.

    I apologize in advance for the spelling and grammar of the text, all the mistakes made were not made on purpose, but only out of ignorance and due to the imperfection of automatic text checking programs.

    The product was provided for writing a review by the store. The review is published in accordance with clause 18 of the Site Rules.

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