CLA-2-85:S:N1:112:882060

Mr. R A McIlvain
Pirelli Cable Corporation
P.O. Box 1097
Greenwood, SC 294648

RE: The tariff classification of Rubber Compounds CV7000, ID8000 from Italy, and copper and/or aluminum Electrical and Mining Cables from Brasil.

Dear Mr. McIlvian:

In your letter dated January 11, 1993, you requested a tariff classification ruling.

Rubber Compounds - CV7000; a peroxide crosslinkable, semi- conductive compound based on polyethylene vinyl acetate copolymer, and ID8000; ethylene-propylene polymer rubber are imported in pellet form. The pellets will be heated and extruded, forming insulation for metal conductors.

The power cable, single conductor 5KV and 8KV cable with stranded class B copper/and or aluminum conductor, triple extruded insulating system consisting of a thermosetting semiconducting conductor shield, thermosetting high dielectric strength Ethylene Propylene Rubber (EPR) based insulation, thermosetting semiconducting insulation shield; helically applied non-magnetic uncoated copper shielding tape, and black PVC jacket will be used in primary and feeder circuits in industrial plants, commercial/office buildings or similar facilities and for power circuits in generating stations.

The mining cable, copper/and or aluminum three conductor 2KV portable cable with flexible stranding, thermosetting high dielectric strength color coded (Black, White, Red) Ethylene Propylene Rubber (EPR) based insulation, cabled with 2 uninsulated grounding conductors and a propylene insulated ground check conductor, and a reinforced extra-heavy duty lead cured thermosetting Neoprene jacket overall is used as trailing cable on ac mining equipment where a ground check conductor is required for ground monitoring. For use where inducted voltages in grounding system will not produce a hazard.

The applicable subheading for the power and mining cables of copper will be 8544.60.4000, Harmonized Tariff Schedule of the United States (HTS), which provides for insulated cables, whether or not fitted with connectors: Other electric conductors, for a voltage exceeding 1,000 V: Other: Of copper... . The duty rate will be 5.3 percent ad valorem. The applicable subheading for the power and mining cables of aluminum will be 8544.60.6000, Harmonized Tariff Schedules of the United States (HTS), which provides for aluminum cables, whether or not fitted with connectors: Other electric conductors, for a voltage exceeding 1,00 V: Other: Other... . The rate of duty will be 4.9 percent ad valorem. With regards to the Rubber Compounds additional information is required: 1. CV7000 - The percentage by weight (net) of each monomer (ethylene - vinyl acetate) in the copolymer.

2. ID8000 - The percentage by weight (net) of each monomer (ethylene - propylene) in the copolymer.

Articles classifiable under subheadings, 8544.60.4000, and 8544.60.6000, HTS, which are products of Brasil are entitled to duty free treatment under the Generalized System of Preferences (GSP) upon compliance with all applicable regulations.

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 transaction.

Sincerely,

Jean F. Maguire
Area Director
New York Seaport