CLA-2-76:RR:NC:N1:118 J88222
Mr. Anthony Cuschieri
President
International Packaging Films, Inc.
54 Tappan Road
Norwood, NJ 07648
RE: The tariff classification of laminated foil products from China.
Dear Mr. Cuschieri:
In your letter dated August 19, 2003, you requested a ruling on tariff classification.
You have described your two laminated products as follows:
1) 9 microns of aluminum (Al) foil and 12 microns of polyester film (PET)
The Al foil equals 59.2% of the weight and the PET equals 40.8%.
The value of the Al foil equals 70% and the PET equals 30%.
2) 9 microns of Al foil and 28 microns of oriented polyethylene film (OPE)
The Al foil equals 47.5% of the weight and the OPE equals 52.5%.
The value of the Al foil equals 65% and the OPE equals 35%.
The adhesive used to bind the components in both items is food grade polyurethane. These laminates are used in the wire and cable industry to be wrapped around the wire or wires prior to the wire being encased/sealed in plastic. The laminates act as a shield to contain electricity within the wire or cable. The Al foil acts as the shielding agent and the PET or OPE gives the Al foil strength and flexibility. The first item is also used in the flexible air conditioning duct industry. The Al foil is used for its flame resistance and the PET film provides strength to the Al foil. The laminates will be imported in widths that range from a maximum of 495 mm to 15 mm.
The applicable subheading for this product will be 7607.20.5000, Harmonized Tariff Schedule of the United States (HTS), which provides for aluminum foil (whether or not printed, or backed with paper, paperboard, plastics or similar backing materials) of a thickness (excluding any backing) not exceeding 0.2 mm: backed: other. The general rate of duty will be Free.
This ruling is being issued under the provisions of Part 177 of the Customs Regulations (19 C.F.R.).
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 Kathy Campanelli at 646-733-3021.
Sincerely,
Robert B. Swierupski
Director,
National Commodity
Specialist Division