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

Mr. John M. Peterson
Neville Peterson LLP
17 State Street, 19th Floor
New York, NY 10004

RE: The tariff classification of thermal conductive grease/paste products from Japan

Dear Mr. Peterson:

In your letter dated January 18, 2011, you requested a tariff classification ruling regarding five different formulations of thermal conductive grease/paste products on behalf of your client Shin-Etsu MicroSi, Inc.

The products, identified as X23-7783D, G751, X23-7756, X23-7762, and G765, are formulated mixtures used to aid electronic component dissipation in printed circuit boards and other board-level electronic components. The products will be imported in bulk form. Samples were submitted in retail size syringes for review with your inquiry and will not be returned.

The products, X23-7783D, G751 and X23-7762, are composed of aluminum, zinc oxide, and organic compounds. Each of the products contains over 5 percent by weight of an aromatic substance.

The product, G765, is composed of aluminum nitride, zinc oxide, and an organic compound containing over 5 percent by weight of an aromatic substance.

The product, X23-7756, is composed of aluminum, zinc oxide, and organic compounds containing less than 5 percent by weight of an aromatic substance.

The applicable subheading for X23-7783D, G751, X23-7762 and G765 will be 3824.90.2800, Harmonized Tariff Schedule of the United States (HTSUS), which provides for Prepared binders for foundry molds or cores; chemical products and preparations of the chemical or allied industries (including those consisting of mixtures of natural products), not elsewhere specified or included: Other: Other: Mixtures containing 5 percent or more by weight of one or more aromatic or modified aromatic substances: Other. The rate of duty will be 6.5 percent ad valorem.

The applicable subheading for X23-7756 will be 3824.90.7000, HTSUS, which provides for Prepared binders for foundry molds or cores; chemical products and preparations of the chemical or allied industries (including those consisting of mixtures of natural products), not elsewhere specified or included: Other: Other: Other: Other: Electroplating chemical and electroless plating solutions and other materials for printed circuit boards, plastics and metal finishings. The rate of duty will be free.

Duty rates are provided for your convenience and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided on World Wide Web at http://www.usitc.gov/tata/hts/.

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 Richard Dunkel (646) 733-3032.

Sincerely,

Robert B. Swierupski
Director
National Commodity Specialist Division