CLA-2-38:RR:NC:2:239 J80371

Mr. Ernest Spinner
BFB Enterprises, Inc.
P.O. Box 28180
393 Wahoo Rd.
Panama City Beach, FL 32411

RE: The tariff classification of WINLEX 4101 and WINLEX 4110 from China.

Dear Mr. Spinner:

In your letter dated November 21, 2002, you requested a tariff classification ruling for WINLEX 4101 (a pentaerythritol ester of rosin) and WINLEX 4110 (a glycerol ester of rosin) which you have stated are used in a wide variety of adhesives due to its stability and polymer capabilities.

The applicable subheading for both products will be 3806.30.0000, Harmonized Tariff Schedule of the United States (HTS), which provides for rosin and resin acids, and derivatives thereof; rosin spirit and rosin oils; run gums: ester gums. The rate of duty will be 6.5 percent 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 National Import Specialist Andrew Stone at 646-733-3032.

Sincerely,

Robert B. Swierupski, Director
National Commodity Specialist Division