CLA-2-36:RR:NC:SP:237 L86933

Ms. Bonne K. Becker
Kamino International
1370 Thorndale Ave
Elk Grove Village, Illinois 60007

RE: The tariff classification of Securiflame Fire-Starter Packets from France.

Dear Ms. Becker:

In your letter dated August 4, 2005, on behalf of Joseph Enterprise, you requested a tariff classification ruling for Securiflame Fire-Starter Packets. The sample is a soft white solid in a small sealed cellophane packet (2-1/4” square x 1/8” thick). The ingredients breakdown by weight is 80% paraffin, 10% urearesin and 10% water. The product is used as a firelighter for barbeques and fireplaces.

You suggested classification in subheading 2901.10.5000, HTSUS, for other saturated acyclic hydrocarbons. Chapter 29 note 1(a) provides for separate chemically defined organic compounds. Because the product consists of paraffin, urearesin and other ingredients it is not considered a separate chemically defined organic compound and must be classified elsewhere in the tariff. Heading 3606, HTSUS, provides for articles of combustible materials as specified in chapter 36 note 2 (including firelighters and the like).

The applicable subheading for Securiflame Fire-Starter Packets will be 3606.90.8000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for other articles of combustible materials as specified in chapter 36 note 2 (including firelighters and the like). The rate of duty will be 5 percent ad valorem. Additional requirements may be imposed on this product by the Consumer Product Safety Commission. You may contact them by writing to the Consumer Product Safety Commission, Washington, D.C. 20207-0001, telephone (301) 504-7923. 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 merchandise is imported. If you have any questions regarding the ruling, contact National Import Specialist Frank Cantone at (646) 733-3038.

Sincerely,


Robert B. Swierupski
Director, National Commodity
Specialist Division