CLA-2-70:OT:RR:NC:N2:226

Ms. Carmen Morrow
Rolls-Royce North America
2001 S. Tibbs Avenue
Speed Code S36 Indianapolis, IN, 46241

RE: The tariff classification of an insulating blanket of glass fibers from Great Britain

Dear Ms. Morrow:

In your letter dated April 8, 2010, you requested a tariff classification regarding an insulation blanket, part number 1-8260-00-00.

A portion of the article was submitted as a sample with your ruling request. The sample was sent for analysis to our U.S. Customs and Border Protection Laboratory. Our laboratory has now completed its analysis.

In your letter you stated that this article will be used as an internal component of a gas turbine aircraft engine. According to the information presented in your ruling request, the “purpose of the insulation blanket is to contain the radiant heat of the exhaust section of the engine” in order to protect the air frame “from excessive heat produced by the turbine.” Thus, this item functions as a heat insulator.

You indicated that the insulation blanket consists of “Q-Fiber Felt” material sandwiched inside a stainless steel outer shell. You stated that the “Q-Fiber Felt” consists of glass fibers – specifically, glass wool.

According to the information presented in your letter, the “Q-Fiber Felt” portion of the blanket performs the insulating function of the product. This material imparts the essential character of the article.

Analysis by our laboratory confirmed that the blanket consists of pads of non-woven glass fibers (glass wool) sandwiched between two sheets of stainless steel.

The applicable subheading for the insulating blanket - consisting of non-woven glass fibers (glass wool) sandwiched between two sheets of stainless steel - will be 7019.39.1090, Harmonized Tariff Schedule of the United States (HTSUS), which provides for glass fibers (including glass wool) and articles thereof… thin sheets (voiles), webs, mats, mattresses, boards and similar non-woven products: other: insulation products. The rate of duty will be 4.9 percent ad valorem.

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 Jacob Bunin at 646-733-3027.

Sincerely,

Robert B. Swierupski
Director,
National Commodity
Specialist Division