Mr. Robert J. Ernst
1125 Indian Street, #15
Bellingham, WA 98225
RE: The tariff classification of cardboard and polyurethane foam
scrap and used pallets from Canada.
Dear Mr. Ernst:
In your letter dated March 17, 1993, you requested a tariff
Munchkin Recycling is a recycling business that collects
cardboard and polyurethane foam waste and scrap. Munchkin also
collects used pallets. Munchkin plans to expand its business
into Canada and import its products into the United States.
The polyurethane foam scrap is obtained primarily from
carpet and mattress dealers. A free collection service is
provided for such dealers who deposit their foam scrap in the
provided storage containers rather than bury it in landfills.
The cardboard waste is collected in much the same manner, but a
monthly service fee is charged. Used pallets are also collected
for a fee. Approximately 40 percent of the pallets are reusable
and they are resold. The non-usable pallets are used to build
The applicable subheading for the polyurethane foam scrap
will be 3915.90.0000, Harmonized Tariff Schedule of the United
States (HTS), which provides for waste, parings and scrap of
other plastics. The rate of duty will be free.
The applicable subheading for the cardboard scrap will be
4707.90.0000, HTS, which provides for waste and scrap of paper or
paperboard: other (than certain enumerated) waste and scrap. The
rate of duty will be free.
The applicable subheading for the non-usable pallets will be
4401.30.4090, HTS, which provides for sawdust and wood waste and
scrap. The rate of duty will be free.
The applicable subheading for the usable pallets will be
4415.20.8000, HTS, which provides for pallets of wood. The rate
of duty will be 16 2/3 percent ad valorem.
Goods classifiable under subheading 4415.20.8000, HTS, which
have originated in the territory of Canada, will be entitled to
an 8 percent ad valorem rate of duty under the United States-
Canada Free Trade Agreement (FTA) upon compliance with all
This ruling is being issued under the provisions of Section
177 of the Customs Regulations (19 C.F.R. 177).
A copy of this ruling letter should be attached to the entry
documents filed at the time this merchandise is imported. If the
documents have been filed without a copy, this ruling should be
brought to the attention of the Customs officer handling the
Jean F. Maguire
New York Seaport