HQ 089456

Sept 10,1991

CLA-2 CO:R:C:F 089456 JGH

Mr. Clyde Reed
Reed Chemical Corporation
233 West Parkway
Pompton Plains, N.J. 07444

RE: Classification of Ground Wood Pulp

Dear Mr. Reed:

This is in reference to your letter of March 29, 1991, concerning the classificaton of ground wood pulp under the Harmonized Tariff Schedule of the United States (HTSUS).


The wood pulp is said to be imported from Germany. It is described as being produced by the mechanically grinding or milling of wood pulp to various particle sizes, designated by different grades. The different grades are said to be obtained by varying the length of time the pulp is in the machine.

A Customs laboratory report of a sample, described it as a white fibrous material, composed of ground-up, chemically bleached sulfate pulp. It was also said to be of a dissolving grade.


Whether the ground wood pulp is classifiable as cellulose in subheading 3912, HTSUS, or chemical wood pulp, dissolving grades, in subheading 4702.00.0040, HTSUS.

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Merchandise imported into the United States is classified under the provisions of the HTSUS, and classification is governed by the principles set forth in the General Rules of Interpretation (GRIs). The Explanatory Notes provide an interpretation of the provisions of the HTSUS on the international level. GRI 1 requires that classification be determined first in accordance with the headings of the HTSUS and any relative section and chapter notes, and (unless otherwise required) according to the remaining GRIs taken in order.

The explanatory notes to chapter 47 note that wood pulp may be semi-bleached, or bleached by chemicals or may be unbleached. A pulp, it is stated, should be regarded as semi-bleached or bleached if, after manufacture, it has been subjected to any treatment intended to increase its degree of whiteness. Pulp, it is noted, may be in powder or flake form. The wood pulp of subheading 4701 is said to be obtained by solely mechanical processes; whereas the chemical wood pulp of subheading 4702 (dissolving grades) is obtained by a chemical process, such as the "sulphate" process. This form of pulp, which can be in powder or flake form, is said to be a source for regenerated cellulose, celluose ethers and esters.

On the other hand, cellulose and its chemical derivatives, in subheading 3912, HTSUS, is said to be obtained by a chemical processing and is no longer considered a fibrous material.


The products in issue are a fibrous form and chemically treated, and are therefore considered dissolving grades of chemical wood pulp. They are classifiable in subheading 4702.00.0040, HTSUS and are duty free.


John Durant, Director
Commercial Rulings Division