CLA-2-39:OT:RR:NC:N4:421
Mr. Ram J. Arvikar
Vectron International Inc.
267 Lowell Road
Hudson, NH 03051
RE: The tariff classification of packaging materials for electronic components from Malaysia
Dear Mr. Arvikar:
In your letter dated November 23, 2010, you requested a tariff classification ruling.
The products are used for packing and shipping electronic components. They include a plastic reel, plastic carrier tape, plastic cover tape, plastic waffle pack and plastic tubes. Illustrations depicting the carrier tape and plastic reel were included with your request.
The carrier tape consists of a strip of polycarbonate plastic that is embossed or molded to incorporate pockets into which small electronic components can be packed. The plastic reel is used to hold the carrier tape, which is wound around the reel. The reel with the carrier tape will be mounted to automatic pick & place equipment that removes the components from the carrier tape and places them on circuit boards. The carrier tape is generally used once and discarded. The reel is said to be capable of reuse.
The cover tape is a self-adhesive tape composed of polyester plastic film that will seal the carrier tape after the electronic components have been placed in the embossed pockets. You indicate in your letter that the cover tape does not exceed 20 centimeters in width. In a telephone conversation with this office you provided additional details about the tape. You state that it is transparent tape, measuring not over 5 centimeters in width and not over 55 meters in length. The cover tape is used once and discarded.
The waffle pack is a plastic sheet that has been embossed with cavities in which electronic components will be placed for shipping and transport. The waffle pack is said to be reusable.
The plastic tubes are used as holders for electronic components. They are said to be reusable. You did not provide a photograph or descriptive literature, but in a telephone conversation with this office you indicated that the “tubes” are in the form of extruded profile shapes that have a uniform cross section from one end to the other and that have not been further worked, e.g., with beveled edges or drilled holes. The holders are complex shapes that are open on both ends and will be sealed with plugs after they are packed with the electronic components. The holders are not imported with the plugs. The holders will be made of polycarbonate.
The applicable subheading for the extruded polycarbonate “tubes” or holders for electronic equipment that are in the form of profile shapes will be 3916.90.5000, Harmonized Tariff Schedule of the United States (HTSUS), which provides for monofilament of which any cross-sectional dimension exceeds 1mm, rods, sticks and profile shapes, whether or not surface worked but not otherwise worked, of plastics: of other plastics: other…other. The rate of duty will be 5.8 percent ad valorem.
The applicable subheading for the self-adhesive plastic cover tape will be 3919.10.2030, Harmonized Tariff Schedule of the United States (HTSUS), which provides for self-adhesive plates, sheets, film, foil, tape, strip and other flat shapes, of plastics...in rolls of a width not exceeding 20 cm: other….transparent tape, not exceeding 55 m in length: not exceeding 5 cm in width. The rate of duty will be 5.8 percent ad valorem.
The applicable subheading for the plastic reel will be 3923.40.0050, HTSUS, which provides for articles for the conveyance or packing of goods, of plastics: spools, cops, bobbins and similar supports, other. The rate of duty will be 5.3 percent ad valorem.
The applicable subheading for the plastic carrier tape and plastic waffle pack will be 3923.90.0080, HTSUS, which provides for articles for the conveyance or packing of goods, of plastics…other. The rate of duty will be 3 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/.
You have inquired about the eligibility of the reels, waffle packs and tubes as instruments of international traffic. This office does not issue rulings as to whether products can be designated as instruments of international traffic pursuant to 19 U.S.C. § 1322(a) and 19 CFR 10.41a. If you wish to receive a ruling on this issue, you should write to Headquarters, U.S. Customs and Border Protection, Director, Commercial & Trade Facilitation Division, Regulations & Rulings, 799 9th Street N.W. – 7th Floor, Washington, DC 20229-1177. Provide complete details about the reusability of the products, including how often each can be reused for international shipment of the contents.
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 Joan Mazzola at (646) 733-3023.
Sincerely,
Robert B. Swierupski
Director
National Commodity Specialist Division