CLA-2-39:RR:NC:2:237 F84707

TARIFF NO: 3905.91.1000

Mr. Brett Ian Harris
Grunfeld, Desiderio, Lebowitz & Silverman
245 Park Avenue, 33rd Floor
New York, New York 10167-3397

RE: Classification of polyvinyl butyral resins from Germany. Dear Mr. Harris:

Your letter of March 20, 2000 requested a classification ruling on behalf of Wacker Polymer Systems of Adrian, Michigan. PioloformR B polyvinyl butyral will be imported in six grades, BN18, BL18, BR18, BM18, BS18 and BL16, each consisting of vinyl alcohol, vinyl acetal and vinyl acetate. No one monomer is 95% or more by weight of the polymer and each polymer contains at least 80% of vinyl acetal, a derivative of vinyl acetate. The applicable subheading for PioloformR BN18, BL18, BR18, BM18, BS18 and BL16 will be 3905.91.1000 HTSUS, for other copolymers of vinyl acetate containing by weight 50 percent or more of derivatives of vinyl acetate. The duty is 4% ad valorem.

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 NIS Frank Cantone at 212-637-7018.


Robert B. Swierupski
National Commodity
Specialist Division